EXHIBIT 6
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 1 of 465
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - - - x
VIRGINIA 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



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 2 of 465
Page 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
7
8
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, ESQUIRE
12
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: JEFFREY S. PAGLIUCA, ESQUIRE
19
LAURA A. MENNINGER, ESQUIRE
20
21
Also Present:
22
James Christe, videographer
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 3 of 465
Page 3
1
2
THE VIDEOGRAPHER: We are now on
3
the record and recording. This begins
4
disk No. 1 in the deposition of
5
Ghislaine Maxwell in the matter of
6
Virginia Giuffre versus Ghislaine
7
Maxwell in the U.S. District Court for
8
the Southern District of New York.
9
Today is April 22, 2016 the time is
10
9:04 a.m.. This deposition is being
11
taken at 575 Lexington Avenue in New
12
York at the request of Sigrid McCawley
13
of Boies Schiller & Flexner.
14
The videographer is James Christe
15
and the court reporter is Leslie Fagin.
16
Will counsel state their appearance and
17
whom they represent and then court
18
reporter swear in Ms. Maxwell.
19
MS. McCAWLEY: My name is Sigrid
20
McCawley with my colleague Meredith
21
Schultz. We are with Boies Schiller &
22
Flexner. We represent Ms. Giuffre.
23
MR. EDWARDS: Brad Edwards. I also
24
represent Ms. Giuffre.
25
MR. CASSELL: Paul Cassell, I also



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 4 of 465
Page 4
1
G Maxwell - Confidential
2
represent Ms. Giuffre.
3
MR. PAGLIUCA: Jeff Pagliuca and
4
Laura Menninger on behalf of Ms.
5
Maxwell.
6
G H I S L A I N E M A X W E L L, called
7
as a witness, having been duly sworn by a
8
Notary Public, was examined and testified as
9
follows:
10
EXAMINATION BY
11
MS. McCAWLEY:
12
Q. Good morning. I'm going to explain
13
some of the rules that will happen with
14
respect to depositions.
15
Have you ever been deposed before?
16
A. I have not.
17
Q. What is going to happen here, we
18
have a court reporter and a videographer.
19
What they do is take down the words that we
20
say so when I ask you a question they will
21
record what you say in response to that. So
22
we have to be mindful that in order for them
23
to do their job we can't talk over each
24
other.
25
Another issue you have to be weary



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 5 of 465
Page 5
1
G Maxwell - Confidential
2
of is that in a response, you can't give a
3
nonverbal response, in other words, nodding a
4
yes or no, they need to hear verbal response
5
so they can record it on their transcript.
6
So that's important for you to remember as we
7
go through the day. If you forget, I will be
8
sure to remind you.
9
Is there anything that would
10
prevent you from giving truthful testimony
11
today?
12
A. There is not.
13
Q. You are not on any medications or
14
anything that would inhibit your ability to
15
remember or give truthful testimony?
16
A. I am not.
17
MR. PAGLIUCA: Could you identify
18
the assistant in the room.
19
MS. McCAWLEY: This is Emma Rosen
20
from our New York office. She is a
21
paralegal.
22
Q. Ms. Maxwell, can you please state
23
your address for the record?
24
A. Currently
25
Q. What is your date of birth?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 6 of 465
Page 6
1
G Maxwell - Confidential
2
A.
3
Q. When did you first recruit a female
4
to work for Mr. Epstein?
5
MR. PAGLIUCA: I object to the form
6
and foundation of the question. I
7
believe this is confidential
8
information. I ask anyone who is not
9
admitted in this case be excused from
10
the room, please.
11
MS. McCAWLEY: So the response to
12
that question would --
13
MR. PAGLIUCA: The subject matter
14
of this question is confidential and I'm
15
designating it as confidential.
16
MS. McCAWLEY: I just want to make
17
that clear for the record.
18
MR. EDWARDS: So we don't delay the
19
deposition I will step out of the room
20
but I think it's important to lay the
21
record that --
22
MR. PAGLIUCA: I'm sorry, you are
23
not admitted in this proceeding so you
24
are not entitled to make any record. If
25
Ms. McCawley wants to make a record she



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 7 of 465
Page 7
1
G Maxwell - Confidential
2
can.
3
MR. EDWARDS: I can make a record
4
right now.
5
MR. PAGLIUCA: Maybe we should get
6
the judge on the phone and talk about
7
it.
8
MR. EDWARDS: The record will be
9
short. This is the precise reason why
10
Ms. Giuffre wants me in this case and
11
I'm unable to effectively represent her
12
at this time because I am unable to have
13
access to the confidential information
14
which includes apparently the entire
15
deposition of Ms. Maxwell. But for the
16
sake of not further delaying this, I
17
will be outside the room.
18
MS. McCAWLEY: Thank you.
19
A. I would like to just -- wait for
20
him to leave.
21
Q. That's fine.
22
A. I would just like to clarify the
23
address. I'm in the process of selling the
24
house so while while I still receive mail
25
there, it's not my actual physical address.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 8 of 465
Page 8
1
G Maxwell - Confidential
2
It's in the process of being sold. It still
3
requires some final paperwork to be done, so
4
just for the purposes of clarity.
5
Q. Do you have a new address where you
6
will be living?
7
A. I do not.
8
Q. For the purpose of the record, if
9
there is something I ask you that you later
10
remember something else or need to correct
11
your testimony in some way, you can do that,
12
just let me know what it is and we will go
13
back to that question and can you clarify.
14
A. Of course. I just wanted to be
15
clear, there is still some paperwork pending
16
for final release, but it's in the process of
17
sale. But I don't have another address
18
currently, so whilst that should still be of
19
record that the mail could be forwarded
20
there, so for purposes of clarity I wanted to
21
be clear.
22
Q. I appreciate that.
23
So Ms. Maxwell, when did you first
24
recruit a female to work for Mr. Epstein?
25
MR. PAGLIUCA: Again. I object to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 9 of 465
Page 9
1
G Maxwell - Confidential
2
form and foundation of the question.
3
Q. You can answer the question.
4
A. First of all, can you please
5
clarify the question. I don't understand
6
what you mean by female, I don't understand
7
what you mean by recruit. Please be more
8
clear and specific about what you are
9
suggesting.
10
Q. Are you a female, is that the sex
11
that you are?
12
A. I am a female.
13
Q. That's what I'm referring to a
14
female and I'm asking you when you first, the
15
very first time you recruited a female to
16
work for Mr. Epstein?
17
A. Again, I don't understand what
18
female -- I am a 54 year old women.
19
Q. I'm not making it age, any age of a
20
female that you recruited to work for Mr.
21
Epstein?
22
A. Again, I was somebody who hired a
23
number of people to work for Mr. Epstein and
24
hiring is one of my functions.
25
Q. And when is the first time you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 10 of 465
Page 10
1
G Maxwell - Confidential
2
hired someone to work for Mr. Epstein, a
3
female?
4
A. As best as I can recollect, a woman
5
the age probably of about 40 or 50 was in
6
sometime in 1992.
7
Q. How long did you work for Mr.
8
Epstein?
9
A. I started working for him at some
10
point in 1992 and the nature of my work
11
relationship with him changed over time so
12
from around 2002, 2003, the work lessened
13
considerably.
14
Q. When did you --
15
MR. PAGLIUCA: Can I interject for
16
a moment. If we are talking about
17
background --
18
MS. McCAWLEY: I'm in the middle of
19
a question. Let me finish it and then
20
can you interject.
21
Q. When you say 2002 to 2003 that the
22
work lessened, when did you complete working
23
for Mr. Epstein; when was the last time you
24
were employed by him, the last date?
25
A. I believe I still was doing --



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 11 of 465
Page 11
1
G Maxwell - Confidential
2
helping him in a very nominal way, maybe an
3
hour or two a year at sometime 2008 and 2009.
4
MR. PAGLIUCA: So if you are going
5
to be talking about general background,
6
I don't need to designate that as
7
confidential. So if you want to have
8
them come back in, that's fine.
9
I assumed by your first question
10
you were going into more sensitive
11
areas. I will leave it up to you, but
12
if this is general background it will
13
not be designated as confidential.
14
MS. McCAWLEY: I appreciate that.
15
I will jump back into my other
16
questions.
17
MR. PAGLIUCA: So we will keep it
18
as confidential.
19
Q. When you were first employed by him
20
in 1992, what were you hired to do?
21
A. First, I was consulting and what I
22
did was I helped with decorating houses and
23
in hiring staff to help run those houses.
24
Q. Did your duties change over the
25
course of 1992 to 2009?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 12 of 465
Page 12
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Object to the form
3
and foundation.
4
A. My job entailed running the homes
5
that he had but much more importantly, most
6
of the houses had construction and so whilst
7
in 1992 there was no construction project,
8
there was construction projects that began
9
after that time and I was in charge not only
10
of hiring architects, I was also in charge of
11
all the filings or overseeing that, like a
12
general contractor would.
13
I also helped with hiring the
14
architects, hiring the builders, reviewing
15
the contracts for the builders, coordinating
16
the building projects, coordinating how the
17
projects would layout, the timing of the
18
projects and all the various materials that
19
they would require to run a very substantial
20
building project. That's the nature of the
21
job I was dealing with.
22
Q. How old was the youngest female you
23
ever hired to work for Jeffrey?
24
MR. PAGLIUCA: Object to the form
25
and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 13 of 465
Page 13
1
G Maxwell - Confidential
2
Q. You can answer.
3
A. I have not any idea exactly of the
4
youngest adult employee that I hired for
5
Jeffrey.
6
Q. When you say adult employee, did
7
you ever hire someone that was under the age
8
of 18?
9
A. Never.
10
Q. Did you ever bring someone who was
11
under -- invite someone under the age of 18
12
to Jeffrey's home, any of his homes?
13
MR. PAGLIUCA: Object to the form
14
foundation.
15
A. Can you repeat the question?
16
Q. Did you ever invite anybody who was
17
under the age of 18 to Jeffrey's homes?
18
MR. PAGLIUCA: Same objections.
19
A. I have a number of friends that
20
have children and friends of mine that have
21
kids and in the invitation of my friends and
22
their kids, I'm sure I may have invited some
23
of my friend's kids to come.
24
Q. Anybody that is not a friend of
25
yours.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 14 of 465
Page 14
1
G Maxwell - Confidential
2
Any female under the age of 18, did
3
you invite them to come to Jeffrey's home?
4
MR. PAGLIUCA: Object to the form
5
and foundation.
6
A. Again, as I said, I am not aware of
7
inviting anybody other than friends of mine
8
who have children to the house.
9
Q. Did you invite Virginia Giuffre to
10
come to Jeffrey Epstein's home when she was
11
under the age of 18?
12
MR. PAGLIUCA: Object to the form
13
and foundation.
14
A. Virginia Roberts held herself out
15
as a masseuse and invited herself to come and
16
give a massage.
17
Q. My question is, did you invite
18
Virginia Roberts when she was under the age
19
of 18 to come to Jeffrey Epstein's home?
20
MR. PAGLIUCA: Object to the form
21
and foundation.
22
A. Again, Virginia Roberts was a
23
masseuse --
24
Q. I'm asking not asking if she was a
25
masseuse. I'm asking if you invited her to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 15 of 465
Page 15
1
G Maxwell - Confidential
2
come to Jeffrey Epstein's home?
3
A. Again, there would be no course to
4
have a conversation with Virginia unless she
5
held herself out to be a masseuse.
6
Q. I'm not asking that question. I'm
7
asking if you invited her to come to Jeffrey
8
Epstein's home when she was under the age of
9
18?
10
A. Again, I repeat, she was a masseuse
11
and in the form and as my job, I was to have
12
people who he wanted for various things
13
including massage. She came as a masseuse.
14
Q. So you invited her to his home to
15
come to give a massage, is that correct?
16
MR. PAGLIUCA: Object to the form
17
and foundation. Misstates the witness'
18
testimony.
19
A. Again, I did not invite Virginia
20
Roberts. She came as a masseuse.
21
Q. She who invited her to come as a
22
masseuse, she just showed up at the front
23
door?
24
MR. PAGLIUCA: Object to the form
25
and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 16 of 465
Page 16
1
G Maxwell - Confidential
2
A. Ms. Roberts held herself out --
3
Q. I'm not asking how she held herself
4
out. I'm asking how she arrived at the home.
5
Did you meet her and invite her to come to
6
the home or how did she arrive there?
7
MR. PAGLIUCA: Object to the form
8
and foundation.
9
A. Ms. Roberts held her to be a
10
masseuse and her mother drove her to the
11
house.
12
Q. When did you first meet Virginia
13
Roberts?
14
A. I don't have a recollection of the
15
first meeting.
16
Q. Do you recall meeting her at
17
Mar-a-Lago?
18
A. Like I said, I don't have a
19
recollection of meeting Ms. Roberts.
20
Q. So you recall Ms. Roberts being
21
brought to the home by her mother, is that
22
your testimony?
23
A. That is my testimony.
24
Q. And that is the first time you met
25
her?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 17 of 465
Page 17
1
G Maxwell - Confidential
2
A. Like I said, I don't recall meeting
3
her the first time. I do remember her mother
4
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 the
13
home with her mother, what happened?
14
A. I spoke to her mother outside of
15
the house and she -- what I don't recall is
16
exactly what happened because I was talking
17
to her mother the entire she was in the
18
house.
19
Q. Did you introduce Ms. Roberts to
20
Jeffrey Epstein?
21
A. I don't recall how she actually met
22
Mr. Epstein. As I said, I spoke to her
23
mother the entire time outside the house.
24
Q. Did you walk Ms. Roberts up to the
25
upstairs location at the Palm Beach house to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 18 of 465
Page 18
1
G Maxwell - Confidential
2
meet Mr. Epstein?
3
MR. PAGLIUCA: Object to the form
4
and foundation.
5
Q. You can answer.
6
A. I just explained.
7
A. I spent the entire time talking to
8
Virginia's mother outside the house so the
9
answer to the question is no.
10
Q. No, did you not walk her up and
11
introduce her to Mr. Epstein?
12
A. I just said no.
13
Q. Did you participate in a massage
14
this first time when she first came to the
15
home and you were speaking with her mother,
16
she was in the home, is that correct, you
17
brought her into the home?
18
MR. PAGLIUCA: Object to the form
19
and foundation.
20
A. I will repeat again, I was standing
21
outside with her mother so very difficult for
22
me to do anything else at that time so no, I
23
did not take her upstairs.
24
Q. Did you participate --
25
A. Virginia lied 100 percent about



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 19 of 465
Page 19
1
G Maxwell - Confidential
2
absolutely everything that took place in that
3
first meeting. She has lied repeatedly,
4
often and is just an awful fantasist. So
5
very difficult for anything to take place
6
that she repeated because I was with her
7
mother the entire time.
8
Q. So did you have -- did you give a
9
massage with Virginia Roberts and Mr. Epstein
10
during the first time Virginia Roberts was at
11
the West Palm Beach house?
12
MR. PAGLIUCA: Object to the form
13
and foundation.
14
Q. Yes or no?
15
A. No.
16
Q. Have you ever given a massage with
17
Virginia Roberts in the room and Jeffrey
18
Epstein?
19
MR. PAGLIUCA: Object to the form
20
and foundation.
21
A. No.
22
Q. Have you ever given Jeffrey Epstein
23
a massage?
24
MR. PAGLIUCA: Object to the form,
25
foundation. And I'm going to instruct



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 20 of 465
Page 20
1
G Maxwell - Confidential
2
you not to answer that question. I
3
don't have any problem with you asking
4
questions about what the subject matter
5
of this lawsuit is, which would be, as
6
you've termed it, sexual trafficking of
7
Ms. Roberts.
8
To the extent you are asking for
9
information relating to any consensual
10
adult interaction between my client and
11
Mr. Epstein, I'm going to instruct her
12
not to answer because it's not part of
13
this litigation and it is her private
14
confidential information, not subject to
15
this deposition.
16
MS. McCAWLEY: You can instruct her
17
not to answer. That is your right. But
18
I will bring her back for another
19
deposition because it is part of the
20
subject matter of this litigation so she
21
should be answering these questions.
22
This is civil litigation, deposition and
23
she should be responsible for answering
24
these questions.
25
MR. PAGLIUCA: I disagree and you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 21 of 465
Page 21
1
G Maxwell - Confidential
2
understand the bounds that I put on it.
3
MS. McCAWLEY: No, I don't. I will
4
continue to ask my questions and you can
5
continue to make your objections.
6
Q. Did you ever participate from the
7
time period of 1992 to 2009, did you ever
8
participate in a massage with Jeffrey Epstein
9
and another female?
10
MR. PAGLIUCA: Objection. Do not
11
answer that question. Again, to the
12
extent you are asking for some sort of
13
illegal activity as you've construed in
14
connection with this case I don't have
15
any problem with you asking that
16
question. To the extent these questions
17
involve consensual acts between adults,
18
frankly, they're none of your business
19
and I will instruct the witness not to
20
answer.
21
MS. McCAWLEY: This case involves
22
sexual trafficking, sexual abuse,
23
questions about her having interactions
24
with other females is relevant to this
25
case. She needs to answer these



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 22 of 465
Page 22
1
G Maxwell - Confidential
2
questions.
3
MR. PAGLIUCA: I'm instructing her
4
not to answer.
5
MS. McCAWLEY: Then we will be back
6
here again.
7
Q. Have you ever given a massage to
8
Mr. Epstein with a female that was under the
9
age of 18?
10
A. Can you repeat the question?
11
Q. Yes. Have you ever given a massage
12
to Mr. Epstein with a female that was under
13
the age of 18?
14
A. No.
15
Q. Have you ever observed Mr. Epstein
16
having a massage given by an individual, a
17
female, who was under the age of 18?
18
A. No.
19
Q. Have you ever observed females
20
under the age of 18 in the presence of
21
Jeffrey Epstein at his home?
22
MR. PAGLIUCA: Object to the form
23
and foundation.
24
A. Again, I have friends that have
25
children --



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 23 of 465
Page 23
1
G Maxwell - Confidential
2
Q. I'm not talking about friends. I'm
3
talking about individuals --
4
MR. PAGLIUCA: I'm going to object
5
to you interrupting the witness who was
6
answering your question. The question
7
was, have you ever seen anyone, female
8
under the age of 18 at the house and
9
that's the question she was answering.
10
If you want to strike that question and
11
ask another question, feel free, but let
12
the witness respond, please.
13
MS. McCAWLEY: I will do that.
14
Q. Have you ever observed a female
15
under the age of 18 at Jeffrey Epstein's home
16
that was not a friend, a child -- one of your
17
friend's children?
18
A. Again, I can't testify to that
19
because I have no idea what you are talking
20
about.
21
Q. You have no idea what I'm talking
22
about in the sense you never observed a
23
female under the age of 18 at Jeffrey
24
Epstein's home that was not one of your
25
friend's children, is that correct?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 24 of 465
Page 24
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Object to the form
3
and foundation.
4
A. How would I possibly know how
5
someone is when they are at his house. You
6
are asking me to do that. I cannot possibly
7
testify to that. As far as I'm concerned,
8
everyone who came to his house was an adult
9
professional person.
10
Q. Are you familiar with the police
11
report that was issued in respect to the
12
investigation in this matter?
13
MR. PAGLIUCA: Object to the form
14
and foundation.
15
Q. Are you familiar with the police
16
report that was used in this matter, the
17
investigation of Jeffrey Epstein, has been
18
produced as a document in this matter?
19
A. I have seen a police report.
20
(Maxwell Exhibit 1, police report,
21
marked for identification.)
22
Q. The police report that you have in
23
front of you, can you turn to page 28 of that
24
report, the numbers are on the top right-hand
25
corner.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 25 of 465
Page 25
1
G Maxwell - Confidential
2
You will see some redactions in
3
this report, Ms. Maxwell, the redacted
4
information is redacted because it reveals
5
the name of a minor, someone who is under the
6
age of 18.
7
On page 28, in the third paragraph,
8
about halfway down, it says,
stated
9
she performed the massage naked. At the
10
conclusion of this massage, Epstein paid
11
$200 for the massage. He explained, I
12
know you are not comfortable put I will pay
13
you if you bring some girls. He told her the
14
younger the better.
stated once tried
15
to bring a 23 year old to Epstein and he
16
stated the female was too old.
17
Have you heard Mr. Epstein use the
18
phrase the younger the better?
19
A. I have no recollection of hearing
20
that.
21
Q. Have you used the phrase in talking
22
to
and asking her to recruit
23
females for Mr. Epstein, the younger the
24
better?
25
MR. PAGLIUCA: Object to the form



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 26 of 465
Page 26
1
G Maxwell - Confidential
2
and foundation of the question.
3
A. First of all, can you break the
4
question apart.
5
Q. Have you used the phrase the
6
younger the better in speaking to
7
and asking her to recruit females for Jeffrey
8
Epstein?
9
MR. PAGLIUCA: Object to the form
10
and foundation.
11
Q. You can answer. It's yes or no.
12
A. No, that's absolutely not true, on
13
the second part of your question, I have not
14
asked Virginia to recruit females and the
15
first part of your question, if you can
16
repeat that again, the question you asked.
17
Q. Will you read back the question.
18
(Record read.)
19
A. I believe I answered the later part
20
of the question. The first part of the
21
question, it's impossible for me to recall
22
events that took place 16 years ago but it
23
doesn't sound like something I would say.
24
Q. On page 28, that same paragraph,
25
was asked how many girls in total she



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 27 of 465
Page 27
1
G Maxwell - Confidential
2
brought to Epstein.
stated that she
3
can remember,
stated that she brought
4
and, it's redacted there, and the victim in
5
this case.
6
Let me ask my question, I have a
7
question pending right now.
8
Are you testifying that you are
9
unaware of any underage, under the age of 18,
10
females coming to Jeffrey Epstein's home to
11
perform massages?
12
MR. PAGLIUCA: Object to the form
13
foundation.
14
A. You need to straddle that question
15
in a different time period. When I was
16
there, at the time I was present, the people
17
that gave Jeffrey, men and women who gave
18
Jeffrey massages were adults over the age of
19
18.
20
Q. Never in your time at any of
21
Jeffrey Epstein's homes were you present when
22
a female under the age of 18 was there to
23
give Jeffrey Epstein a massage?
24
MR. PAGLIUCA: Object to the form
25
and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 28 of 465
Page 28
1
G Maxwell - Confidential
2
A. First of all, as I said when I was
3
present --
4
Q. It is a yes or no.
5
A. No, it is not.
6
Q. You can answer the question in full
7
but please provide yes or no as an initial
8
matter.
9
A. I cannot answer yes or no, it's not
10
bounded by time. It's entirely possible I
11
could have been in a room or even in the
12
vicinity of Palm beach when somebody came and
13
I would not know. How would I know when
14
somebody was in the house. There is no way I
15
can know.
16
Q. Did you stay at Jeffrey Epstein's
17
home when you were in Palm Beach?
18
A. Most of the time.
19
Q. So how is it that you wouldn't know
20
if there was a female in the home under the
21
age of 18 if you were staying there?
22
A. Well, first of all, when I was
23
staying there, the house is actually quite
24
large and I have a very busy job and I had an
25
office with a door so the door would be shut



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 29 of 465
Page 29
1
G Maxwell - Confidential
2
and I would be working. I'm not responsible
3
for what Jeffrey does and I don't always pay
4
attention to what happens in the house. I'm
5
very busy.
6
Q. So you're testifying that you never
7
observed a female under the age of 18 at
8
Jeffrey Epstein's West Palm Beach home?
9
MR. PAGLIUCA: Object to the form
10
and foundation.
11
A. I already answered that question, I
12
believe.
13
Q. You didn't answer my question.
14
A. I did.
15
Q. Did you observe a female under the
16
age of 18 at Jeffrey Epstein's home in Palm
17
Beach?
18
A. Like I said, I work, I don't sit
19
there and watch people coming in and out of
20
the house. I cannot possibly tell you if I'm
21
in the home that somebody was there that I
22
did not see, I cannot comment on it, I have
23
no idea.
24
Q. Did you observe females at Jeffrey
25
Epstein's home that were laying out topless



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 30 of 465
Page 30
1
G Maxwell - Confidential
2
in the back of the home, in other words
3
without a shirt on?
4
A. So that's just another of
5
Virginia's lies. So let's be clear, at the
6
time when I was there and present, frequently
7
at the house, it was unusual to see people
8
without their clothes on.
9
Q. When you say unusual, did you
10
observe people without their clothes at
11
Jeffrey Espstein's home?
12
A. Can I answer. Sometimes people in
13
the privacy of a house and swimming pool, I
14
have seen people from time to time take their
15
top off. I have seen people from time to
16
time do that. Very unusual. Naked people
17
around the people at any frequent period of
18
time, I have never seen.
19
Q. Were they under the age of 18?
20
A. As I was saying, people when I was
21
in the house, were of adult age, if they were
22
children, friends of my family or friends
23
that were there, they may well have been
24
because I have nieces and nephews under the
25
age of 18, I cannot testify to anybody else



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 31 of 465
Page 31
1
G Maxwell - Confidential
2
-- just another one of Virginia's many
3
fictitious lies and stories to make this a
4
salacious event to get interest and press.
5
It's absolute rubbish.
6
Q. Were you in charge of hiring
7
individuals to provide massages for Jeffrey
8
Epstein?
9
A. My job included hiring many people.
10
There were six homes. As I sit here, I hired
11
assistants, I hired architects, I hired
12
decorators, I hired cooks, I hired cleaners,
13
I hired gardeners, I hired pool people, I
14
hired pilots, I hired all sorts of people.
15
In the course and a very small part
16
of my job was from from time to time to find
17
adult professional massage therapists for
18
Jeffrey.
19
Q. When you say adult professional
20
massage therapists, where did you find these
21
massage therapists?
22
A. From time to time I would visit
23
professional spas, I would receive a massage
24
and if the massage was good I would ask that
25
man or woman if they did home visits.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 32 of 465
Page 32
1
G Maxwell - Confidential
2
Q. Did you ever hire a masseuse that
3
was under the age of 18?
4
MR. PAGLIUCA: Object to the form
5
and foundation.
6
Q. Did you?
7
A. Again, I don't hire massage
8
therapists, so that was not my job.
9
Q. You just said you did, you just
10
said you hired massage therapists for Jeffrey
11
Epstein, I'm asking if you hired a massage
12
therapist who was under the age of 18?
13
A. Let me correct myself. When I
14
meant hire, I didn't mean hire in the way you
15
are doing it. What I say is that I went to
16
spas and I met people and if they did home
17
visits, Jeffrey would then, in fact, hire
18
them. I'm not responsible for hiring
19
someone. And they were not full-time, so
20
it's not a correct characterization.
21
Q. Did you ever, your term is meet,
22
did you ever meet a person that was under the
23
age of 18 that you -- that Jeffrey then hired
24
as a masseuse?
25
MR. PAGLIUCA: Object to the form



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 33 of 465
Page 33
1
G Maxwell - Confidential
2
and foundation.
3
A. First of all, Virginia Roberts who
4
you are referring to was a masseuse aged 17,
5
we all now know, so your story that you keep
6
pushing out to the press that she was a 15
7
year old -- you and I both know was a lie,
8
correct.
9
Q. You are not sentencing my question.
10
A. You and I both know that was a lie,
11
correct.
12
Q. You are not answering my question.
13
I'm asking you whether you ever met a female
14
under the age of 18 that Jeffrey then hired
15
as a masseuse?
16
MR. PAGLIUCA: Object to the form
17
and foundation.
18
A. The only person I can talk about
19
who clearly was a massage age 17, a masseuse,
20
was Virginia.
21
Q. Did you meet her and then introduce
22
her to Jeffrey?
23
A. I don't know. I already testified
24
I don't recall meeting her.
25
(Maxwell Exhibit 2, email, marked



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 34 of 465
Page 34
1
G Maxwell - Confidential
2
for identification.)
3
Q. So I'm showing you a document that
4
we have marked as Maxwell Exhibit 2. It's a
5
document you produced in this matter labeled
6
confidential GM 00109. It's dated Sunday
7
June 12, 2011. It's from Jeffrey Epstein to
8
you. If you can turn to page 4 -- sorry, can
9
you turn to the first page, the cover page
10
initially which is 00109. If you look under
11
the time stamp it says, June 12, 2011 at 4:12
12
p.m., it says
13
Is that your email address?
14
A. It is.
15
Q. Under that it says, Thank you. I
16
have it now and I'm working on a letter, a
17
little, I will send the final version
18
tomorrow and what ever it is will be
19
factually accurate.
20
Do you see that on page 1?
21
A. I do.
22
Q. Then I would like you to turn to
23
page 4 please. The second paragraph down on
24
page 4, it states, After some thought, I
25
recall that I first met Ms. Roberts when she



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 35 of 465
Page 35
1
G Maxwell - Confidential
2
was working at a premier resort claiming to
3
be 18 years old and a professional masseuse?
4
MR. PAGLIUCA: What line are you
5
on, counsel.
6
MS. McCAWLEY: Second paragraph
7
down.
8
MR. PAGLIUCA: I got it.
9
Q. Is that a statement that you wrote?
10
A. It appears to be.
11
Q. So does that correct your testimony
12
that you did meet Ms. Roberts at Mar-a-Lago?
13
A. Again, this was written in, when
14
were you saying?
15
Q. 2011.
16
A. So by 2011, Ms. Roberts had already
17
perpetrated so many lies and stories it's
18
hard for me to accurately tell you today what
19
I remember back then. As I sit here today,
20
the testimony I give you today, I do not
21
recollect it.
22
Q. Do you have a reason to say that
23
this document that you wrote is incorrect?
24
A. It's in 2011, I can't possibly tell
25
you what I remember in 2011.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 36 of 465
Page 36
1
G Maxwell - Confidential
2
Q. Are you questioning that this
3
document is incorrect, this document -- this
4
email that you wrote?
5
A. I wrote an email. I was trying to
6
be accurate, so who knows, with all the
7
rubbish that you guys have put out in the
8
press that I read, maybe in the moment I
9
wrote it a memory came to me that I don't
10
know, but as I sit here today and the
11
testimony I gave you today is I don't
12
recollect it.
13
Q. Does this refresh your recollection
14
that you recalled meeting Ms. Roberts at
15
Mar-a-Lago?
16
A. It does not.
17
Q. So your testimony today is that you
18
don't remember meeting Ms. Roberts at
19
Mar-a-Lago?
20
A. I do not.
21
I just want to clarify, when you
22
read so much stuff and so much rubbish that
23
comes out from Virginia Roberts, you don't
24
know what's up and down, at the time I wrote
25
this I believe I had a memory but as I sit



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 37 of 465
Page 37
1
G Maxwell - Confidential
2
here today I do not.
3
Q. Ms. Maxwell, when did you first
4
meet
?
5
MR. PAGLIUCA: Object to the form
6
and foundation.
7
A. I have no idea when I met her.
8
Q. Do you know how old she was when
9
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 old
13
when you first met her?
14
MR. PAGLIUCA: Object to the form
15
and foundation.
16
A.

18
may have been in the house when Jeffrey was
19
in the house. I have no idea how old she
20
was.
21
Q. I understand
22
23
I'm asking if
was 13
24
years old when you first met her?
25
A. I have no idea.




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 38 of 465
Page 38
1
G Maxwell - Confidential
2
Q. Was she under 18 when you first met
3
her?
4
A. I have no idea how old she was when
5
I first met her.
6
Q. Did she look like a child when you
7
first met her?
8
A. I don't remember what she looked
9
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 I
12
saw her.
13
Q. When was the first time you met
14
her?
15
A. Again, I just told you, I don't
16
recall the first time I met her.
17
Q. Did
travel with you
18
on Jeffrey's planes?
19
A. I wouldn't remember if
was on
20
the plane or not.
21
Q. Did you ever have sex with
22
23
A. No.
24
Q. Did you ever observe Jeffrey having
25
sex with
?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 39 of 465
Page 39
1
G Maxwell - Confidential
2
A. No.
3
Q. Were you aware that Jeffrey was
4
having sexual contact with
when
5
she was 13 years old?
6
MR. PAGLIUCA: Object to the form
7
and foundation.
8
A. I would be very shocked and
9
surprised if that were true.
10
Q. Were you in the house when
11
was in the house in a private area
12
with Jeffrey Epstein?
13
MR. PAGLIUCA: Object to the form
14
and foundation.
15
A. Can you repeat the question.
16
Q. Were you ever in the Palm Beach
17
house when Jeffrey Epstein was in the house
18
with
?
19
MR. PAGLIUCA: Object to the form
20
and foundation.
21
A. I've already testified that I have
22
met her and that she was there
23
I don't understand what your
24
question is asking.
25
Q. So you have never seen



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 40 of 465
Page 40
1
G Maxwell - Confidential
2
3
MR. PAGLIUCA: Object to the form
4
and foundation.
5
Q. Is that your testimony?
6
A. I already said I don't recall all
7
the times I've seen her and I have no memory
8
of that.
9
Q. Have you ever seen
in
10
the house with Jeffrey Epstein
11
12
MR. PAGLIUCA: Object to the form
13
and foundation.
14
A. I just told you I don't recall
15
seeing
16
Q. Were you ever involved in an orgy
17
with
?
18
A. No, absolutely not.
19
Q. Can you tell me, do you know an
20
individual by the name of
?
21
A. I do.
22
Q. How did you meet
?
23
A. At some point she was a friend of
24
Jeffrey's and I recall meeting her at some
25
point.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 41 of 465
Page 41
1
G Maxwell - Confidential
2
Q. Did you hire her?
3
A. First of all, I don't hire girls
4
like that, so let's be clear, I already
5
testified to that, and I have no idea what
6
you are referring to.
7
Q. When you say girls like that, what
8
do you mean?
9
A. I hire people who are professional
10
at the house. You are asking if I hired
11
somebody to do what, I don't know what you
12
are talking about. I hired people to work in
13
the homes.
14
Q. What was Nadia Marcinkova doing?
15
MR. PAGLIUCA: Object to the form
16
and foundation.
17
A. I have no idea what Nadia
18
Marcinkova was doing. I didn't hire her and
19
I don't know what you are referring to.
20
Q. You met Nadia Marcinkova?
21
A. I testified I did.
22
Q. Did she work for Jeffrey Epstein?
23
A. I have no idea what she did.
24
Q. Have you flown on planes with Nadia
25
Marcinkova?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 42 of 465
Page 42
1
G Maxwell - Confidential
2
A. I don't recollect. I don't know if
3
I did.
4
Q. How many times have you flown on
5
Jeffrey Epstein's planes?
6
A. Too many times.
7
Q. More than 300?
8
A. I really couldn't tell you how
9
many.
10
Q. More than 400?
11
A. Again, I said I cannot tell you how
12
many, a lot.
13
Q. How many times with
14
15
A. I already testified, I have no
16
idea.
17
Q. How old was
when
18
she first became involved with Jeffrey?
19
A. I have no idea.
20
Q. Was she 14?
21
MR. PAGLIUCA: Object to the form
22
and foundation.
23
A. I have no idea.
24
Q. Did she look like a child the first
25
time you met her?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 43 of 465
Page 43
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Object to the form
3
and foundation. Asked and answered.
4
Q. Did she look like a child the first
5
time you met
?
6
A. I don't know what you mean if she
7
looked like a child.
8
Q. Did she look like she was under the
9
age of 18?
10
A. No.
11
Q. Did she look like she was under the
12
age of 16?
13
A. I just testified -- first of all, I
14
couldn't tell you how old she was, she didn't
15
like like a child, leave it at that.
16
Q. Did you know that she was a child?
17
MR. PAGLIUCA: Object to the form
18
and foundation.
19
A. I just answered I did not know how
20
old she was and she looked like an adult.
21
Q. In the times that you traveled with
22
her on Jeffrey Epstein's planes, did you ever
23
ask her how old she was?
24
MR. PAGLIUCA: Object to the form
25
and foundation. Assumes facts not in



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 44 of 465
Page 44
1
G Maxwell - Confidential
2
evidence. The witness already testified
3
she doesn't remember.
4
Q. You can answer that question.
5
Did you ever ask her on the many
6
flights you were with her or the many times
7
you were with her at the house?
8
A. First of all, I don't know I was on
9
many flights with her, you are making stories
10
up again as usual. And secondly, if I was on
11
a flight with her, there would not be any
12
reason why I would ask her how old she was.
13
Q. You don't recollect having any
14
conversation with her about her age?
15
A. I already testified to that.
16
Q. Do you know what
17
was hired to do for Jeffrey?
18
A. I already testified I didn't know
19
she was hired and I don't know that she did
20
anything. I don't know how to answer that
21
question.
22
Q. Was
at the house,
23
the Palm Beach house, when you were present
24
at that house?
25
MR. PAGLIUCA: Object to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 45 of 465
Page 45
1
G Maxwell - Confidential
2
foundation.
3
A. I have no recollection of her being
4
at the house at the same time as me.
5
Q. When did you first meet
6
7
A. I already told you I don't recall.
8
Q. Do you recall anything about
9
10
A. That she was tall and blond.
11
Q. Do you recall
12
interacting with other females at the house?
13
A. No, I do not.
14
Q. Did you arrange to get a visa for
15
to come into this country?
16
MR. PAGLIUCA: Object to the form
17
and foundation.
18
A. Absolutely not.
19
Q. Did Jeffrey arrange for a visa for
20
?
21
MR. PAGLIUCA: You need to give me
22
a break so I can interpose an objection.
23
Object to the form and foundation.
24
Q. You can answer.
25
A. What was the question?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 46 of 465
Page 46
1
G Maxwell - Confidential
2
Q. Did Jeffrey arrange for a visa for
3
?
4
A. I don't know what Jeffrey did. I
5
cannot testify what Jeffrey did.
6
Q. Was
involved in sex with
7
Jeffrey 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
involved with sex with
14
Jeffrey and girls over the age of 18?
15
MR. PAGLIUCA: Same objection.
16
A. I have no idea.
17
Q. Did
recruit other girls for
18
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
23
A. No.
24
Q.
25
A. I have no idea.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 47 of 465
Page 47
1
G Maxwell - Confidential
2


3
4
A. I have no idea.
5
Q. Are you a pilot?
6
A. I am.
7
Q. Have you flown with
?
8
A. I have.
9
Q. Have you flown with
10
11
A. What do you mean by flown?
12
Q. Have you been on planes with her?
13
A. I already testified I don't recall
14
having her on a plane with me.
15
Q. Do you know
?
16
A. I do.
17
Q. When did you first meet her?
18
A. I don't recall exact dates.
19
Q. Did you meet her with the purpose
20
of hiring her to work for Jeffrey or having
21
Jeffrey hire her?
22
MR. PAGLIUCA: Object to the form
23
and foundation.
24
A. No.
25
Q. What was her relationship with




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 48 of 465
Page 48
1
G Maxwell - Confidential
2
Jeffrey?
3
MR. PAGLIUCA: Object to the form
4
and foundation.
5
A. I don't know exactly the nature of
6
her relationship but she worked for him.
7
Q. What did she do?
8
MR. PAGLIUCA: Object to the form
9
and foundation.
10
A. At the time she when was with him I
11
believe she traveled with him and helped with
12
his travel arrangements.
13
Q. Did she bring girls to the house to
14
give massages to Jeffrey?
15
MR. PAGLIUCA: Object to the form
16
and foundation.
17
A. I don't know what
did.
18
Q. So you never observed
19
bringing girls to the home to give massages
20
to Jeffrey?
21
MR. PAGLIUCA: Object to the form
22
and foundation.
23
A. I don't understand the question,
24
what did you mean bring?
25
Q. Did you ever observe



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 49 of 465
Page 49
1
G Maxwell - Confidential
2
inviting, bringing, walking anyone into the
3
home to give a massage for Jeffrey?
4
MR. PAGLIUCA: Object to the form
5
and foundation.
6
A. I don't recollect anything like
7
that.
8
Q. Are you aware that
was
9
a co-conspirator, named as a co-conspirator
10
in the case involving Jeffrey Epstein?
11
MR. PAGLIUCA: Object to the form
12
and foundation and also calls for a
13
legal conclusion.
14
MS. McCAWLEY I'm just asking if she
15
is aware of that.
16
A. I am aware.
17
Q. Who paid
?
18
A. I have no idea.
19
Q. Did you ever arrange payment for
20
any of the employees at the home?
21
MR. PAGLIUCA: Object to the form.
22
A. What do you mean by arrange?
23
Q. Were you ever in charge or
24
responsible for paying individuals at the
25
home, that worked there?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 50 of 465
Page 50
1
G Maxwell - Confidential
2
A. People had salaries and they were
3
paid by the office.
4
Q. Did you ever pay any individual,
5
did you ever hand an individual cash for work
6
they performed?
7
MR. PAGLIUCA: Object to the form.
8
A. Can you be more specific about what
9
you are asking me.
10
Q. Did you ever hand any individual
11
who was working at the home cash as payment
12
for something that they performed at the
13
home?
14
MR. PAGLIUCA: Object to the form.
15
A. To the best of my recollection
16
there were very few times where I would leave
17
some cash for people for work performed.
18
Q. And what type of work was being
19
performed where you would be doing that?
20
A. If I left cash for the pool guy, I
21
would have left potentially some cash for the
22
gardener, potentially for exercise
23
instructors and sometimes for massage
24
therapy.
25
Q. How much were the massage



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 51 of 465
Page 51
1
G Maxwell - Confidential
2
therapists paid?
3
MR. PAGLIUCA: Object to the form
4
and foundation.
5
A. They get paid between 100 and $200.
6
Q. Did it vary based on what sexual
7
acts they performed?
8
MR. PAGLIUCA: Object to the form
9
and foundation.
10
A. No. It varied depending how much
11
time, some massage therapists charge more and
12
some charge less.
13
Q. Did the massage therapists that
14
were hired to come to the home perform sexual
15
acts for Jeffrey Epstein?
16
MR. PAGLIUCA: Object to the form
17
and foundation.
18
A. What are you asking me?
19
Q. I'm asking if the massage
20
therapists --
21
A. Are you asking me about underage
22
girls?
23
Q. I'm asking in general, did any of
24
the massage therapists in the home --
25
A. Are you asking if they were paid



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 52 of 465
Page 52
1
G Maxwell - Confidential
2
for sexual acts.
3
Q. I'm asking if they performed sexual
4
acts?
5
MR. PAGLIUCA: Object to the form
6
and foundation.
7
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
MR. PAGLIUCA: Objection. Form and
19
foundation.
20
To the extent any of this is asking
21
for to your knowledge any consensual sex
22
act that may or may not have involved
23
you, I'm instructing you not to answer
24
the question.
25
Q. I'm not asking about consensual sex



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 53 of 465
Page 53
1
G Maxwell - Confidential
2
acts. I'm asking whether any of the massage
3
therapists performed sexual acts for Mr.
4
Epstein, as I have just described?
5
A. I have never seen anybody have
6
sexual intercourse with with Jeffrey, ever.
7
Q. I'm not asking about sexual
8
intercourse. I'm asking about any sexual
9
act, touching of the breast -- did you ever
10
see -- can you read back the question?
11
(Record read.)
12
A. I'm not addressing any questions
13
about consensual adult sex. If you want to
14
talk about what the subject matter, which is
15
defamation and lying, 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
A. I have just answered the question.
25
Q. No, you haven't.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 54 of 465
Page 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 the
6
question.
7
A. Let's move on.
8
Q. I'm in charge of the deposition. I
9
say when we move on and when we don't.
10
You are here to respond to my
11
questions. If you are refusing to answer the
12
court will bring you back for another
13
deposition to answer these questions.
14
Do you understand that?
15
MR. PAGLIUCA: You don't need to
16
threaten the witness.
17
MS. McCAWLEY: I'm not threatening
18
her. I'm making sure the record is
19
clear.
20
MR. PAGLIUCA: Certainly can you
21
apply to have someone come back and the
22
court may or may not have her come back
23
again.
24
Again, she is not answering
25
questions that relate to adult consent



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 55 of 465
Page 55
1
G Maxwell - Confidential
2
sex acts. Period. And that's the
3
instruction and we can take it up with
4
the court.
5
Q. Ms. Maxwell, are you aware of any
6
sexual acts with masseuses and Jeffrey
7
Epstein that were nonconsensual?
8
A. No.
9
Q. How do you know that?
10
A. All the time that I have been in
11
the house I have never seen, heard, nor
12
witnessed, nor have reported to me that any
13
activities took place, that people were in
14
distress, either reported to me by the staff
15
or anyone else. I base my answer based on
16
that.
17
Q. Are you familiar with a person by
18
the name of
?
19
A. I am.
20
Q. Has
given a statement
21
to police about you performing sexual acts on
22
her?
23
A. I have not heard that.
24
Q. Has
given a statement
25
to police about Jeffrey Epstein performing



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 56 of 465
Page 56
1
G Maxwell - Confidential
2
sexual acts on her?
3
MR. PAGLIUCA: Object to the form
4
and foundation.
5
A. I have not heard that.
6
Q. How do you know
?
7
A.
10
Q. Was
under the age of
11
18?
12
MR. PAGLIUCA: Object to the form
13
and foundation.
14
A. I don't recall how old
15
was.
16
Q. Did she tell police that Jeffrey
17
Epstein assaulted her sexually?
18
MR. PAGLIUCA: Object to the form
19
and foundation.
20
A. I never heard that.
21
Q. Did
recruit or bring
22
girls to the home that were under the age of
23
18?
24
MR. PAGLIUCA: Object to the form
25
and foundation and I think this has been





Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 57 of 465
Page 57
1
G Maxwell - Confidential
2
asked and answered already.
3
Q. You can answer the question.
4
A. I have no idea what
5
did.
6
Q. You never observed
7
with girls under the age of 18 at Jeffrey's
8
home?
9
MR. PAGLIUCA: Object to the form
10
and foundation.
11
A. The answer is no, I have no idea.
12
Q. Do you know
?
13
A. I do.
14
Q. What is your relationship with
15
16
MR. PAGLIUCA: Object to the form.
17
A. What do you mean what is my
18
relationship.
19
Q. Are you friendly with him, how do
20
you know him?
21
A. He is the husband of
.
22
Q. Is
one of your friends?
23
A. Yes.
24
Q. Did you ever send Virginia to
25
to give him a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 58 of 465
Page 58
1
G Maxwell - Confidential
2
massage?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. No.
6
Q. Did you ever instruct Virginia
7
Roberts to have sex with
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I have never instructed Virginia to
11
have sex with anybody ever.
12
Q. How old was
when she
13
met Jeffrey?
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
A. I have no idea.
17
Q. What's she under the age of 18?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I just testified I have idea how
21
old she was.
22
Q. You testified she was your friend.
23
You don't know how old she was when she met
24
Jeffrey?
25
A. That happened sometime in the '70s,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 59 of 465
Page 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 30
4
years ago?
5
Q. You don't ask the questions here,
6
Ms. Maxwell.
7
What about
, when
8
did you first meet
9
A. I don't recall the exact date.
10
Q. Did you hire
11
A. I don't hire people, she came to
12
work at the house to answer phones.
13
Q. Where did you meet her?
14
A. I just testified, I don't recall
15
exactly when I met her.
16
Q. Was one of your job
17
responsibilities to interview people that
18
would be then hired by Jeffrey?
19
A. That was one of my
20
responsibilities.
21
Q. Do you recall interviewing
22
A. I don't recall the exact interview,
23
no.
24
Q. Do you know what tasks
was
25
hired to performance?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 60 of 465
Page 60
1
G Maxwell - Confidential
2
A. She was tasked to answer
3
telephones.
4
Q. Did you ever ask her to rub
5
Jeffrey's feet?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I believe that I have read that,
9
but I don't have any memory of it.
10
Q. Did you ever tell
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



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 61 of 465
Page 61
1
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
A. I'm just saying, I cannot recall
7
the exact conversation. I give career advice
8
and I have done that.
9
Q. Did you ever have
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
to
17
massage
?
18
A. I don't believe -- I have no
19
recollection of it.
20
Q. Did you ever have sexual contact
21
with
22
MR. PAGLIUCA: Object to the form
23
and foundation. You need to give me an
24
opportunity to get in between the
25
questions.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 62 of 465
Page 62
1
G Maxwell - Confidential
2
Anything that involves consensual
3
sex on your part, I'm instructing you
4
not to answer.
5
Q. Did you ever have sexual contact
6
with
7
A. Again, she is an adult --
8
Q. I'm asking you, did you ever have
9
sexual contact with
10
A. I've just been instructed not to
11
answer.
12
Q. On what basis?
13
A. You have to ask my lawyer.
14
Q. Did you ever have sexual contact
15
with
that was not consensual on
16
part?
17
MR. PAGLIUCA: You can answer
18
nonconsensual.
19
A. I've never had nonconsensual sex
20
with anybody.
21
Q. Not
?
22
MR. PAGLIUCA: Objection.
23
A. I just testified I never had
24
nonconsensual sex with anybody ever, at any
25
time, at anyplace, at any time, with anybody.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 63 of 465
Page 63
1
G Maxwell - Confidential
2
Q. So if
were to testify that
3
she did not consent to a sexual act that you
4
participated in --
5
A. I just told you I have never ever
6
under any circumstances with anybody, at any
7
time, in anyplace, in any form had
8
nonconsensual relations with anybody.
9
Q. Did you introduce
10
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I've, again, read that
14
claimed that she met or that she said she met
15
. I don't know if I was the one
16
who made the introduction or not.
17
Q. Do you know a female by the name of
18
19
A. I do.
20
Q. How do you know her?
21
A.
22
Q. So she worked for you?
23
A. Yes.
24
Q. Did you hire her?
25
A. Again, Jeffrey hired people.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 64 of 465
Page 64
1
G Maxwell - Confidential
2
Q. Did you have sex with her?
3
MR. PAGLIUCA: This is the same
4
instruction about consensual or
5
nonconsensual.
6
Q. Was
under the age of 18 when
7
you hired her?
8
A. No. I didn't hire her, as I said,
9
Jeffrey did.
10
Q. Did
ever have sex with
11
Jeffrey?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. How would I know what somebody else
15
did.
16
Q. You weren't involved in the sex
17
between Jeffrey,
and yourself?
18
A. We already --
19
Q. Were you involved with sex between
20
Jeffrey,
and yourself?
21
MR. PAGLIUCA: Everyone is talking
22
over each other. You heard the
23
question.
24
Again, you you know what the
25
instruction is. If there is any



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 65 of 465
Page 65
1
G Maxwell - Confidential
2
consensual issue involved, I instruct
3
you not to answer.
4
A. Moving on.
5
Q. So you are refusing to answer that
6
question?
7
A. I've been instructed by my lawyer.
8
Q. Did you ever have sex with Jeffrey,
9
Virginia and yourself when Virginia was
10
underage?
11
A. Absolutely not.
12
MR. PAGLIUCA: We've been going for
13
about an hour. I would like to take a
14
five-minute break, please.
15
MS. McCAWLEY: I'm almost done.
16
MR. PAGLIUCA: You are not going to
17
allow a break.
18
MS. McCAWLEY: As soon as I get
19
through my line of questioning, which is
20
perfectly appropriate.
21
Q. Did
travel with you and
22
Jeffrey to Europe?
23
A. I'm sure she did.
24
Q. What is she doing today?
25
A. I have no idea.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 66 of 465
Page 66
1
G Maxwell - Confidential
2
Q. Do you speak to her regularly now,
3
do you speak to her?
4
A. No.
5
Q. Do you know where she lives?
6
A. No.
7
Q. Do you know what country she lives
8
in?
9
A. No.
10
Q. Where is the last place you knew
11
that she lived?
12
A. Last place I knew for sure was in
13
Los Angeles.
14
Q. When did she stop working for you?
15
A. 2001, 2002.
16
Q. What tasks did she performance for
17
you?
18
A. She helped me with moving in and
19
out of houses, construction, she was a
20
general help, she helped with buying things
21
that needed to be purchased, if I needed her
22
to stand in for me during meetings, it was a
23
very wide ranging job.
24
Q. Did she ever bring females to
25
perform massages for Jeffrey?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 67 of 465
Page 67
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. What are you asking me?
5
Q. Did
was it ever
6
responsibility to bring females to the house
7
for the purposes of massaging Jeffrey?
8
A.
job was to help me with the
9
houses and work in homes. It was not her job
10
to whatever you just said, bring masseuses.
11
Q. Did she do that?
12
A. I have no recollection. I have no
13
idea.
14
Q. Did you pay
or did Jeffrey pay
15
her?
16
A. Jeffrey.
17
Q. Do you recall how much she was
18
paid?
19
A. I do not.
20
MS. McCAWLEY: I think we can take
21
a break now.
22
THE VIDEOGRAPHER: It's 10:02 and
23
we are off the record.
24
(Recess.)
25
THE VIDEOGRAPHER: It's now 10:18.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 68 of 465
Page 68
1
G Maxwell - Confidential
2
We are back on the record and starting
3
disk No. 2.
4
Q. Ms. Maxwell, I asked you about
5
Virginia Roberts earlier.
6
Can you describe what Virginia
7
Roberts' duties were when she was with Mr.
8
Epstein?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I believe that Virginia was a
12
masseuse.
13
Q. Was Virginia required to dress up
14
in any way for massages?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I have no idea.
18
Q. Did you provide Virginia with
19
outfits to wear for certain massages?
20
A. I have no idea what you are talking
21
about.
22
Q. For example, did you ever provide
23
Virginia with a school girl outfit to wear
24
for a massage?
25
A. I have no idea what you are talking



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 69 of 465
Page 69
1
G Maxwell - Confidential
2
about.
3
Q. So you didn't provide her with
4
that?
5
A. As I just testified, I have no idea
6
what you are talking about.
7
Q. I was trying to interpret whether
8
you didn't understand what a school girl
9
outfit was or you are saying that didn't
10
happen?
11
A. I clearly know what a school girl
12
outfit is. I have no recollection of
13
providing anybody with a school girl outfit.
14
Q. Did you have a set of outfits used
15
by the massage therapists that would include
16
things like a school girl outfit or a black
17
patent leather outfit or anything of that
18
nature?
19
MR. PAGLIUCA: Object to the form
20
and foundation.
21
A. That would be just another one of
22
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



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 70 of 465
Page 70
1
G Maxwell - Confidential
2
that you kept in the Palm Beach house?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. First of all what do you mean.
6
Q. A laundry basket that contained sex
7
toys in it?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. Can you ask the question again?
11
Q. Did you have a laundry basket that
12
contained sex toys in it, in the Palm Beach
13
House?
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
Q. Did you have a laundry basket of
17
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 a
21
laundry basket of sex toys.
22
Q. Do you recollect having sex toys at
23
the Palm Beach house?
24
A. You have to define what are you
25
talking about.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 71 of 465
Page 71
1
G Maxwell - Confidential
2
Q. A sex toy meaning a vibrator of
3
some kind, sometimes they are called dildos,
4
of that nature, anything like that?
5
A. I don't recollect anything that
6
would formally be a dildo, anything like
7
that.
8
Q. How would you describe sex toys?
9
A. I wouldn't describe sex toys.
10
Q. Did you have anything that was of
11
an electronic nature that would be used
12
during sex?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I have no idea what you are
16
referring to.
17
(Maxwell Exhibit 3, transcript,
18
marked for identification.)
19

21














Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 72 of 465
Page 72
1
G Maxwell - Confidential
2

4




















.

































Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 73 of 465
Page 73
1
G Maxwell - Confidential
2








16

































Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 74 of 465
Page 74
1
G Maxwell - Confidential
2

5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. First I have to read this.
8
Q. Sure.
9
MS. McCAWLEY: I will stop the
10
clock while the witness is reading.
11
MR. PAGLIUCA: No.
12
MS. McCAWLEY: Yes, if she is going
13
to read the whole document, I will stop
14
the clock.
15
MR. PAGLIUCA: If you give her
16
documents to refresh her recollection,
17
we are on the clock here.
18
MS. McCAWLEY: Then we will take it
19
up with the judge.
20
MR. PAGLIUCA: Read whatever you
21
need to answer the question.
22
MS. McCAWLEY: I'm going to set the
23
document aside and I'm just go to ask
24
you a question, independent of the
25
document.





Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 75 of 465
Page 75
1
G Maxwell - Confidential
2
Q. Do you recall having a basket full
3
of sex toys?
4
A. I already told you I did not.
5
Q. We were talking a moment ago about
6
Ms. Roberts and her position as a masseuse,
7
do you know what she was paid for working as
8
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 during
13
the massage appointments with Jeffrey Epstein
14
and Virginia Roberts?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. No.
18
Q. Were you ever present to view a
19
massage between Jeffrey Epstein and Virginia
20
Roberts?
21
A. I don't recollect ever seeing
22
Virginia and Jeffrey in a massage situation.
23
Q. Do you ever recollect seeing them
24
in a sexual situation?
25
A. I never saw them in a sexual



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 76 of 465
Page 76
1
G Maxwell - Confidential
2
situation.
3
Q. Did you ever participate in sex
4
with Virginia Roberts and Jeffrey Epstein?
5
A. I never ever at any single time at
6
any point ever at all participated in
7
anything with Virginia and Jeffrey. And for
8
the record, she is an absolute total liar and
9
you all know she lied on multiple things and
10
that is just one other disgusting thing she
11
added.
12
Q. Did you help her obtain an
13
apartment in Palm Beach to live in?
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
Q. Was that part of your
17
responsibilities for Jeffrey?
18
A. First of all, I didn't know she had
19
an apartment in Palm Beach. I only learned
20
that from the many times you guys have gone
21
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 for
24
Jeffrey, to get her is a cell phone as part
25
of her masseuse obligations?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 77 of 465
Page 77
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I don't know what that means,
5
masseuse obligation, I don't know what you
6
are referring to. Would you like to ask the
7
question properly?
8
Q. I think it was proper. I will ask
9
it again.
10
Did you ever assist in getting
11
Virginia Roberts a cell phone to use during
12
the time that she worked for Jeffrey Epstein?
13
A. I have no recollection of doing
14
anything of that nature.
15
Q. Did you ever tell Virginia that you
16
wanted her to have a cell phone so that she
17
could be on call regularly?
18
A. I have no recollection of that
19
conversation.
20
Q. How often would Virginia come over
21
to the house in Palm Beach to give massages?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Ask the question again, please.
25
Q. How often did Virginia Roberts come



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 78 of 465
Page 78
1
G Maxwell - Confidential
2
over to the house in Palm Beach to give
3
massages?
4
A. It's important to understand that I
5
wasn't with Jeffrey all the time. In fact, I
6
was only in the house less than half the
7
time, so I cannot testify to when I wasn't in
8
the house how often she came when I wasn't
9
there.
10
What I can say is that I barely
11
would remember her, if not for all of this
12
rubbish, I probably wouldn't remember her at
13
all, except she did come from time to time
14
but I don't recollect her coming as often as
15
she portrayed herself.
16
Q. How many times a day on an average
17
day would Jeffrey Epstein get a massage?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. When I was at the house and when I
21
was there with him, he received a massage, on
22
average, about once a day.
23
Q. Just once?
24
A. Yes.
25
Q. Were there days when he received



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 79 of 465
Page 79
1
G Maxwell - Confidential
2
four or five?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. When I was present at the house, I
6
never saw something like that.
7
Q. Do you know if Virginia was
8
required to be on call at all times to come
9
to the house if Jeffrey wanted her there?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I have no idea of the arrangements
13
that Virginia made with Jeffrey.
14
Q. When Virginia was in New York,
15
would Virginia sleep at Jeffrey's mansion in
16
New York?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I don't recollect her being in New
20
York and I have no idea where she slept.
21
Q. You don't ever remember seeing
22
Virginia Roberts in New York?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. I would barely recollect her at



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 80 of 465
Page 80
1
G Maxwell - Confidential
2
all, except for this story.
3
Q. Do you recall Virginia Roberts
4
calling you because she was having a medical
5
crisis and you and Jeffrey taking her to the
6
hospital?
7
A. I have heard this absurd story and
8
if any part of it were true I would remember
9
that. I do not.
10
Q. You don't remember taking her to
11
the hospital?
12
A. It's not that I don't remember it,
13
it didn't happen.
14
Q. How do you know it didn't happen?
15
A. That's the sort of memory you would
16
recall.
17
Q. Do you recall, you said you don't
18
remember her being at the New York mansion.
19
When you were in New York would you stay at
20
the New York mansion with Jeffrey?
21
A. I stayed from time to time.
22
Q. Do you recall Virginia being at the
23
New York mansion when
came to
24
visit?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 81 of 465
Page 81
1
G Maxwell - Confidential
2
form and foundation.
3
A. Like I told you, I don't recall her
4
being at the house at all.
5
Q. How many homes does Jeffrey have?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. When I was working for him, I think
9
he had six maybe.
10
Q. Would Virginia stay with him in
11
those homes?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I can only testify for when I was
15
present with him and I cannot say what she
16
did when I wasn't present with him.
17
Q. When you were present, would
18
Virginia stay in the homes with him?
19
A. I don't recall her staying in the
20
houses.
21
Q. Did you train Virginia on how to
22
recruit other girls for massages?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. No.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 82 of 465
Page 82
1
G Maxwell - Confidential
2
Q. Did you train Virginia on how to
3
recruit other girls to perform sexual
4
massages?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. No. And it's absurd and her entire
8
story is one giant tissue of lies and
9
furthermore, she herself has -- if she says
10
that, you have to ask her about what she did.
11
Q. Does Jeffrey like to have his
12
nipples pinched during sexual encounters?
13
MR. PAGLIUCA: Objection to form
14
and foundation.
15
A. I'm not referring to any advice on
16
my counsel. I'm not talking about any adult
17
sexual things when I was with him.
18
Q. When Jeffrey would have a massage,
19
would he request that the masseuse pinch his
20
nipples while he was having a massage?
21
A. I'm not talking about anything with
22
consensual adult situation.
23
Q. What about with underage --
24
A. I am not aware of anything.
25
Q. You are not aware of Jeffrey



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 83 of 465
Page 83
1
G Maxwell - Confidential
2
Epstein ever having sex with an underage
3
minor and asking them to pinch his nipples?
4
A. I am not.
5
Q. So I'm going to direct you to, I
6
believe it's Maxwell Exhibit 1, the police
7
report.
8
Are you aware that over 30 under
9
age minors gave testimony to police that they
10
were engaged in sexual acts during,
11
quote-unquote, massages.
12
MR. PAGLIUCA: The witness needs to
13
find Exhibit 1. Exhibit 1 -- if you can
14
hand me that please.
15
Q. So now with respect to the police
16
report, are you aware that over 30 underage
17
girls, meaning under the age of 18 gave
18
reports to police that they were assaulted
19
sexually by Jeffrey Epstein during massages?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I read the police report. That's
23
all I can testify to.
24
Q. Are you aware of what is in the
25
police report? Are you aware that there were



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 84 of 465
Page 84
1
G Maxwell - Confidential
2
30 girls --
3
A. I did not count the number of girls
4
and I did read the police report. I can only
5
testify to what I read.
6
Q. So you are aware that the police
7
report contains reports from 30 underage
8
girls?
9
A. I can't testify to what the girls
10
said. I can only testify to the fact that I
11
read a police report that stated that.
12
Q. Were you working for Jeffrey -- you
13
said you worked for him off an on until 2009,
14
is that correct?
15
A. I helped out from time to time.
16
Q. So you were working with him during
17
the time period when these underage girls
18
were visiting Jeffrey's home?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I was not -- what year, I need
22
years.
23
Q. How about let's say 2005?
24
A. I'm not sure I was at the house at
25
all in 2005, maybe one day, maybe.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 85 of 465
Page 85
1
G Maxwell - Confidential
2
Q. How about 2004?
3
A. I was present for his mother's --
4
his mother died in 2004 so I was there for
5
his mother's death and the funeral and I was
6
at the house maybe a handful of days, again.
7
Q. I would like to direct you to, you
8
have it pulled together now, it's page 39,
9
Bates stamped Giuffre 00040?
10
A. Can you repeat that, please.
11
Q. Sure. 00040.
12
A. Yes.
13
Q. At the top of that document, about
14
three lines down, you see the redacted
15
portions where there is black so it blacks
16
out the name.
17
A. I see black redacted portions.
18
Q. That's a black redaction of the
19
name of the minor and there is -- I will
20
represent for the record that's what it is.
21
You can contest that but I'm not asking about
22
the name of the minor.
23
Five lines down, it says, She was
24
just 16 years of age.
25
Do you see that?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 86 of 465
Page 86
1
G Maxwell - Confidential
2
A. I have to read that, if you want me
3
to testify to some things.
4
Q. I'm asking if you see where it
5
says, She was just 16 years old.
6
A. No, I have to read it.
7
Q. It's five line downs on the first
8
paragraph.
9
A. I do see that.
10
Q. Then the next paragraph down, it
11
says, this is the next full paragraph, it
12
says, Epstein entered the room, introduced
13
himself, Epstein lay on the table and told
14
her to get comfortable, blank could not
15
remember if he was naked or if he entered the
16
room with a towel. Blank stated she provided
17
the massage wearing her panties. She
18
continued rubbing his thighs and feet. Blank
19
advised he turned over on his back and
20
continued to rub his legs with oil. Epstein
21
touched her breast and began to masturbate.
22
I asked if she knew what circumcised and
23
uncircumcised meant. She stated circumcised
24
is when the penis had no foreskin.
25
Then jumping down to the next



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 87 of 465
Page 87
1
G Maxwell - Confidential
2
paragraph, it says, Blank became upset,
3
crying hysterically and stated she was paid
4
and also instructed to have sex with Epstein
5
and
by Epstein.
6
Do you see that there?
7
A. I do.
8
Q. Are you aware that there were
9
underage minors in the Palm Beach house that
10
were required to give sexual massages to
11
Jeffrey Epstein?
12
MR. PAGLIUCA: Objection to the
13
form and foundation. This has been
14
asked and answered already. Now you are
15
just reading a document.
16
MS. McCAWLEY: I am allowed to take
17
this deposition.
18
A. I already testified --
19
Q. Are you aware there were underage
20
girls, 30 of them, in this police report that
21
were assaulted by Jeffrey Epstein in the Palm
22
Beach house during the time you are working
23
there?
24
A. I am aware that Virginia has
25
lied repeatedly --



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 88 of 465
Page 88
1
G Maxwell - Confidential
2
Q. I'm not asking about Virginia. I'm
3
asking if you are aware that there were over
4
30 underage girls who gave reports to police
5
officers during the time you worked for
6
Jeffrey Epstein. Are you aware of that?
7
MR. PAGLIUCA: Counsel, what is
8
your factual basis for asserting there
9
are 30 underaged people who gave
10
reports?
11
MS. McCAWLEY: I don't have to
12
answer that.
13
MR. PAGLIUCA: Are you representing
14
as an officer of the court that you have
15
personal knowledge that there are 30
16
people referenced in these police
17
reports?
18
MS. McCAWLEY: That's my
19
understanding, that there are 30 girls.
20
MR. PAGLIUCA: How is that your
21
understanding if these are redacted
22
reports?
23
MS. McCAWLEY: By reading through
24
the reports.
25
MR. PAGLIUCA: So you have personal



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 89 of 465
Page 89
1
G Maxwell - Confidential
2
knowledge there are 30 people --
3
MS. McCAWLEY: Just like can you if
4
you read through -- I will not argue
5
with you counsel.. she can answer yes or
6
no.
7
Q. Are you aware there were over 30
8
individuals who were minors who gave reports
9
to police just like the one we just read that
10
they were sexually assaulted by Jeffrey
11
Epstein in the Palm Beach home during the
12
years that you were working with him?
13
MR. PAGLIUCA: Objection to the
14
form and foundation. You can answer if
15
you have knowledge.
16
A. I already testified I was limited
17
in the house, a couple of days, there is no
18
way I knew. I have read these reports. I
19
cannot testify to 30. Given the experience
20
I've had with Virginia's lies, it's very hard
21
for me to testify about what I see. I can
22
tell from you my personal knowledge I did not
23
know what you are referring to.
24
Q. You did not know there were
25
underage girls in the home that were being



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 90 of 465
Page 90
1
G Maxwell - Confidential
2
assaulted by Jeffrey Epstein during the time
3
you were working there?
4
A. Based on the lies that I have
5
already been told, I cannot comment on any --
6
Q. Are you saying these 30 girls are
7
lying when they gave these reports to police
8
officers?
9
A. I'm not testifying to their lies.
10
I'm testifying to Virginia's lies.
11
Q. I am not asking about Virginia's
12
lies.
13
A. I can only testify to Virginia's
14
lies. I can testify to having read these
15
reports. I cannot testify to anything else
16
about them.
17
Q. So your testimony is that during
18
the time you were working there, you did not
19
know that these minor children were being
20
abused in the home while you were there?
21
A. What I have already told you and I
22
will repeat, I was in the house very limited
23
times, very few times. I do not know what
24
you are referring to. I've read these
25
reports but based on the lies that Virginia



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 91 of 465
Page 91
1
G Maxwell - Confidential
2
has perpetrated, cannot tell you what is true
3
or factual or not.
4
Q. You said you were in the home a
5
very limited time, so average in the year for
6
example, 2004, how many times would you have
7
been in his Palm Beach home?
8
A. Very hard for me to state but very
9
little.
10
Q. How about his New York home?
11
A. Same.
12
Q. Were you his girlfriend in that
13
year, in 2004?
14
A. Define what you mean by girlfriend.
15
Q. Were you in a relationship with him
16
where you would consider yourself his
17
girlfriend?
18
A. No.
19
Q. Did you ever consider yourself his
20
girlfriend?
21
A. That's a tricky question. There
22
were times when I would have liked to think
23
of myself as his girlfriend.
24
Q. When would that have been?
25
A. Probably in the early '90s.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 92 of 465
Page 92
1
G Maxwell - Confidential
2
Q. In your responsibilities in working
3
for Jeffrey, would you book massages for him
4
on any given day so that he would have a
5
massage scheduled? Would you take a call for
6
example and book a massage for him?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
Q. You can answer.
10
A. Typically, that was not my
11
responsibility. He would either book the
12
massage himself or one of his other
13
assistants would do that.
14
Q. From time to time you had to do
15
that?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. Like I said, typically it was
19
somebody else's responsibility.
20
Q. If you were unable to book a girl
21
for a massage on a given day, would that mean
22
that you were responsible for giving him a
23
sexual massage?
24
MR. PAGLIUCA: Objection to the
25
form and foundation and I instruct you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 93 of 465
Page 93
1
G Maxwell - Confidential
2
not to answer any questions about any of
3
your consensual adult sexual activity.
4
Q. So you are not going to answer that
5
question?
6
A. You just heard my counsel.
7
Q. 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
MR. PAGLIUCA: Object to the form
12
and foundation.
13
A. Repeat the question and break it
14
out.
15
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
Q. Have you ever said to anybody --
21
A. 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.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 94 of 465
Page 94
1
G Maxwell - Confidential
2
Q. I'm asking the questions. I know
3
what this case is about. I'm trying to -- I
4
will ask you questions if you don't
5
understand the question I can break it down
6
for you. I'm happy to do that.
7
A. Break it down a lot please.
8
Q. I will do that.
9
The question is, have you ever said
10
to anybody that you recruit other girls --
11
A. Why don't you stop there.
12
Q. Let me finish my question.
13
Have you ever said to anybody that
14
you recruit girls to take the pressure off
15
you, so you won't have to have sex with
16
Jeffrey, have you said that?
17
That's the question?
18
A. You don't ask me questions like
19
that. First of all, you are trying to trap
20
me, I will not be trapped. You are asking me
21
if I recruit, I told you no. Girls meaning
22
underage, I already said I don't do that with
23
underage people and as to ask me about a
24
specific conversation I had with language, we
25
talking about almost 17 years ago when this



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 95 of 465
Page 95
1
G Maxwell - Confidential
2
took place. I cannot testify to an actual
3
conversation or language that I used with
4
anybody at any time.
5
Q. Have you ever said to anybody that
6
you recruit other females over the age of 18
7
to take the pressure off you to having to
8
have sex with Jeffrey?
9
A. I totally resent and find it
10
disgusting that you use the word recruit. I
11
already told you I don't know what you are
12
saying about that and your implication is
13
repulsive.
14
Q. Answer my question.
15
A. I just did.
16
Q. Have you ever said to anybody that
17
you recruit females --
18
A. I don't recruit anybody.
19
Q. That's an answer. So you never
20
said that?
21
A. I'm testifying that I cannot
22
testify to an actual language --
23
Q. It's a yes or no.
24
A. I will not testify to an actual
25
statement made 17 years ago, so I cannot



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 96 of 465
Page 96
1
G Maxwell - Confidential
2
testify to actual language.
3
Q. So you won't testify to anything
4
I'm asking you 17 years ago about a statement
5
you made. How do you know it's 17 years ago?
6
A. We are talking about a time in
7
2000, right?
8
Q. Have you ever said that to anybody?
9
A. I'm 54 years old so you are asking
10
me in my entire life, what words are you
11
asking me in my entire life?
12
Q. Your entire life is limited by the
13
time you were with Jeffrey, this is the
14
question.
15
A. Let's time limit the question you
16
are asking me.
17
Q. So from, let's say, I think you
18
said you started with him in 1992, is that
19
correct, and finished with him in 2009.
20
So from 1992 to 2009 have you ever
21
said to anybody that you recruit other and we
22
will start with girls to take the pressure
23
off you to have sex with Jeffrey?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 97 of 465
Page 97
1
G Maxwell - Confidential
2
A. First of all I resent and despise
3
the world recruit. Would you like to define
4
what you mean by recruit and by girls, you
5
mean underage people. I never had to do
6
anything with underage people. So why don't
7
you reask the question in a way that I am
8
able to answer it.
9
Q. I'm asking if you ever said that to
10
anybody. So if you don't understand the word
11
recruit and you never used that word then the
12
answer to that question would be no.
13
A. I have no memory as I sit here
14
today having used that word.
15
Q. Did you ever meet an underage girl
16
in London to introduce her to Jeffrey to
17
provide him with a massage?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. Run that past me one more time.
21
Q. Did you ever meet an underage girl
22
in London to introduce her to Jeffrey to
23
perform a massage?
24
MR. PAGLIUCA: Same objection.
25
A. Are you asking me if I met anybody



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 98 of 465
Page 98
1
G Maxwell - Confidential
2
that was underage in London specifically to
3
provide a massage to Jeffrey, is that your
4
question?
5
Q. Yes.
6
A. No.
7
Q. Do you know who
is?
8
A. I don't recall her right now.
9
Q. Do you know if -- strike that.
10
During the time that you were
11
working for Jeffrey, did you ever observe any
12
foreign females, so in other words, not from
13
the United States, that were brought to
14
Jeffrey's home to perform massages?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. Females, what age are we talking?
18
Q. Any age.
19
A. Can you repeat the question?
20
Q. During the time you were working
21
for Jeffrey, did you ever observe any foreign
22
females of any age that were at Jeffrey's
23
home to perform a massage?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 99 of 465
Page 99
1
G Maxwell - Confidential
2
A. Are you asking me if any foreigner,
3
not an American person, gave Jeffrey a
4
massage?
5
Q. Yes.
6
A. Well, as I sit here today, I can't
7
think of anyone who is foreign. Certainly --
8
I just can't think of anybody right this
9
second.
10
Q. How about any foreign girls who
11
were under the age of 18?
12
A. I already testified to not knowing
13
anything about underage girls.
14
Q. Were there foreign girls who were
15
brought to Jeffrey's home by
16
for the purposes of providing massages?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I am not aware of
bringing
20
girls. I have not no idea what you are
21
talking about.
22
Q. You have never been around foreign
23
girls who are under the age of 18 at
24
Jeffrey's homes?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 100 of 465
Page 100
1
G Maxwell - Confidential
2
form and foundation.
3
A. I already testified about not
4
knowing about underage girls.
5
Q. Did you provide any assistance with
6
obtaining visas for foreign girls that were
7
under the age of 18?
8
A. I've never participated in helping
9
people of any age to get visas.
10
Q. Did Jeffrey, was it Jeffrey's
11
preference to start a massage with sex?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I think you should ask that
15
question of Jeffrey.
16
Q. Do you know?
17
A. I don't believe that was his
18
preference. I think -- you have to
19
understand, a massage -- perhaps you are not
20
really familiar with what massage is.
21
Q. I am, I don't need a lecture on
22
massage.
23
A. I think you do.
24
MR. PAGLIUCA: No question pending.
25
She will ask you another question now.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 101 of 465
Page 101
1
G Maxwell - Confidential
2
A. Massage is for health benefits.
3
Q. When did you first meet Jeffrey?
4
A. Some point in 1991.
5
Q. And did Jeffrey know your father?
6
A. No.
7
Q. How were you introduced to Jeffrey?
8
A. Some friend introduced us.
9
Q. Can you describe your relationship
10
back in 1991, was it friendship or was it
11
girlfriend relationship or was it a work
12
relationship, what was your relationship in
13
1991?
14
A. It was just friendly.
15
Q. Then I believe you testified you
16
began working for him in 1992, is that
17
correct?
18
A. Yes.
19
Q. In 1992 I know you gave me the
20
description of the work that you were
21
performing for him, how much was he paying
22
you, do you remember?
23
A. I don't recall.
24
Q. Do you know for example in 2001 how
25
much he was paying you?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 102 of 465
Page 102
1
G Maxwell - Confidential
2
A. I don't recall.
3
Q. Did it change over the years or did
4
the payment remain the same?
5
A. I believe over the course of time
6
it increased a little bit.
7
Q. Was that the -- was that payment
8
the payment that -- was the payment made with
9
respect to the jobs, the work you were
10
performing for Jeffrey, was that your sole
11
income at that time?
12
MR. PAGLIUCA: I object to the
13
form. I'm also going to instruct you
14
not to answer about sources of -- your
15
personal sources of income outside of
16
Mr. Epstein at all.
17
MS. McCAWLEY: What's the basis for
18
that?
19
MR. PAGLIUCA: It's confidential,
20
it's not part of this lawsuit.
21
MS. McCAWLEY: We have a protective
22
order and it is part of this lawsuit
23
with respect to our damage claims.
24
MR. PAGLIUCA: It's not and, in
25
fact, you are not entitled to ask



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 103 of 465
Page 103
1
G Maxwell - Confidential
2
financial information of a defendant in
3
this kind of case, in a defamation case
4
unless and until there is a finding that
5
you are entitled to punitive damages.
6
That is clear in New York case law, both
7
state and Federal.
8
MS. McCAWLEY: We disagree on that
9
point and we will come back to that.
10
Q. From the source of payment from the
11
source of Jeffrey, from your work, can you
12
give me a range on that, do you know was it
13
over $100,000?
14
A. I just testified I don't recall.
15
Q. You don't don't know if it was
16
$500,000?
17
A. It was less than that.
18
Q. Somewhere between 100 and 500,
19
would that be fair to say?
20
A. I believe it was between 100 and
21
$200,000.
22
Q. Did Jeffrey during the time that
23
you were working for him purchase a town home
24
for you?
25
A. The subject of the townhouse is, I



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 104 of 465
Page 104
1
G Maxwell - Confidential
2
worked for it and I had a loan, we did loans.
3
Q. So a loan through Jeffrey?
4
A. I don't recall the exact
5
transaction.
6
Q. Did he purchase for you a
7
helicopter during the time you were working
8
for him?
9
A. It was his helicopter.
10
Q. When did you obtain your pilot
11
license?
12
A. I believe it was '98 or '99.
13
Q. Was that for both airplanes and
14
helicopters or just helicopters?
15
A. Just helicopters.
16
Q. Have you ever flown
17
on your helicopter?
18
A. That is another one of Virginia's
19
lies.
20
Q. The question is have you ever done
21
that?
22
A. I have never flown
23
at any time ever, in any helicopter,
24
in any place, any time, in any state, in any
25
country, at any time anywhere.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 105 of 465
Page 105
1
G Maxwell - Confidential
2
Q. Have you ever had dinner with
3
at Jeffrey's home, at any
4
of Jeffrey's homes?
5
A. No, I don't believe so.
6
Q. Have you traveled on Jeffrey's
7
planes with
?
8
A. Yes, I have.
9
Q. Would that have been in 2002?
10
A. It's very hard for me to recollect
11
exact dates but that sounds about right.
12
Q. Was that during the time that
13
Virginia was working for Jeffrey?
14
A. I don't know that Virginia ever did
15
work for Jeffrey. I don't exactly know if
16
she testified to her so-called duties, we
17
know she is a serial liar so I can't testify
18
to what she did or didn't do. So I object to
19
that characterization of her. So repeat the
20
question, please.
21
Q. Can you read the question back?
22
(Record read.)
23
Q. You can answer the question.
24
A. What was the question again?
25
Q. When you were traveling on the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 106 of 465
Page 106
1
G Maxwell - Confidential
2
plane with
, was that during
3
the time, it was 2002, that you were on a
4
flight with
was that during the time
5
Virginia was working for Jeffrey?
6
MR. PAGLIUCA: Object to the form.
7
Misstates the witness' answer and if you
8
can answer the question, you can answer
9
it.
10
A. Well, like I said, I don't recall
11
exactly when I flew with him. I don't recall
12
when Virginia, we know what Virginia claims
13
when she left, so I can't answer the
14
question. I have no idea.
15
Q. Do you know
?
16
A. I do.
17
Q. How long have you known him?
18
A. A very long time.
19
Q. Since you were a child?
20
A. I really -- it's so long, it's
21
really a long time ago. I just don't recall.
22
Q. Do you remember how you first met
23
him?
24
A. No, I do not.
25
Q. Did you introduce him to Jeffrey?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 107 of 465
Page 107
1
G Maxwell - Confidential
2
A. That would be another of Virginia's
3
lies and the lies you perpetrate. I never
4
introduced
to Jeffrey Epstein
5
at any time ever, so just add that the to
6
long list of lies.
7
Q. Did Jeffrey know
?
8
A. Clearly he knew him. I think we
9
have that answer but how -- yeah.
10
Q. Do you know how Jeffery met
11
12
A. I do not know Jeffrey met
13
What I do know is that I did not
14
introduce them. That is one of the many
15
lies. Are we tallying all the lies?
16
Q. Do you know when Jeffrey met
17
18
A. I do not know when Jeffrey met
19
.
20
Q. Did you ever introduce
21
to any girls under the age of 18 who
22
were not friends of yours children?
23
A. I have not introduced
24
to anyone that I am aware of other than
25
friends of mine who have kids under that age



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 108 of 465
Page 108
1
G Maxwell - Confidential
2
that he may have met socially through me.
3
Q. Did you ever introduce
4
to Virginia in London?
5
A. I understand her story about
6
but again, her tissue of lies is extremely
7
hard to pick apart what is true and what
8
isn't. Actually I wouldn't recollect her at
9
all but for her tissue stories about this
10
situation.
11
Q. So did you ever introduce
12
to Virginia in London?
13
A. I have no recollection.
14
Q. Did Virginia ever stay at your home
15
in London, your town home?
16
A. I know she claims she did but if
17
you are asking me here today to remember
18
specifically, I cannot.
19
Q. Do you remember taking a trip with
20
Virginia to travel over to Europe, including
21
London?
22
A. So I have seen her reports and I
23
have seen the plane reports. I see she says
24
she was on that but again, I really have no
25
recollection of her.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 109 of 465
Page 109
1
G Maxwell - Confidential
2
Q. Did you know that she was 17 at the
3
time of that trip?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I have --
7
Q. Did you know she was 17 at the time
8
of that trip?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I didn't even know she was on the
12
trip.
13
Q. Did you hold her passport for her
14
when she was traveling?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I have no recollection whatsoever
18
of her even being on the trip nor holding her
19
passport.
20
(Maxwell Exhibit 4, picture, marked
21
for identification.)
22
Q. I'm showing you what we marked as
23
Maxwell Exhibit 4.
24
Can you take a look at that picture
25
for me?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 110 of 465
Page 110
1
G Maxwell - Confidential
2
A. I've looked at it.
3
Q. Are you in that picture?
4
A. I am.
5
Q.
7
A. It is.
8
MR. PAGLIUCA: I don't believe this
9
has been produced to us in discovery by
10
you.
11
MS. McCAWLEY: The picture?
12
MR. PAGLIUCA: Yes.
13
MS. McCAWLEY: It has.
14
MS. MENNINGER: Is it the same
15
exact photograph.
16
MS. McCAWLEY: I believe so. We
17
will find one. The picture has been
18
produced a number of times.
19
MR. PAGLIUCA: I've seen different
20
iterations of this, I don't believe I
21
have ever seen this.
22
MS. McCAWLEY: We had them blow it
23
up on a page so she could see it. We
24
could use an article.
25
While you are looking for that, I




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 111 of 465
Page 111
1
G Maxwell - Confidential
2
will skip ahead. Hold that until we can
3
find one that has the Bates range on it.
4
Q. Do you recall Virginia being at
5
your London town home?
6
A. I do not.
7
Q. Do you recall going to dinner with
8
, Jeffrey Epstein and Virginia
9
Roberts in London, at any time?
10
A. I do not.
11
Q. Do you recall going to a place
12
called

, Jeffrey
13
Epstein and yourself and Virginia Roberts?
14
A. I would just like to state for the
15
record

I do not have any recollection of it
21
and I doubt it actually happened.
22
Q. You don't recall that.
23
Do you recall taking Virginia
24
shopping when you were in London to buy an
25
outfit to meet








Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 112 of 465
Page 112
1
G Maxwell - Confidential
2
A. No, I don't.
3
Q. Where in your town home -- we will
4
come back to that.
5
Do you have guest bedrooms in your
6
town home in London?
7
A. I do.
8
Q. How many?
9
A. Two.
10
Q. Did
ever visit
11
Jeffrey and you in New York?
12
A. Yes.
13
Q. Do you remember him visiting you
14
and Jeffrey in New York in the spring of
15
2001?
16
A. Again, I can't testify to any
17
specific dates.
18
Q. So you don't have a recollection of
19
that?
20
A. I have a recollection -- you've
21
asked me if I have a recollection of being in
22
New York but if you are asking for a date, I
23
cannot confirm that date.
24
Q. Do you remember
being
25
present in New York for a party where



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 113 of 465
Page 113
1
G Maxwell - Confidential
2
was also present?
3
A. I don't recollect.
4
Q. Do you recall ever giving
5
a gift of a puppet that was in the
6
same -- that looked like him?
7
A. I never gave him a gift of a
8
puppet.
9
Q. Did Jeffrey ever give him a gift of
10
a puppet?
11
A. No, not that I am aware of.
12
Q. Have you ever given him any gifts?
13
MR. PAGLIUCA: Objection,
14
foundation.
15
A. I know
--
16
Q. Have you ever given him any gifts
17
that you remember when he came to Jeffrey's
18
home in New York?
19
A. I don't recall giving him any gifts
20
in New York.
21
(Maxwell Exhibit 5, picture, marked
22
for identification.)
23
Q. I think I directed you to page
24
0034.
25
Is that a picture that was taken at



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 114 of 465
Page 114
1
G Maxwell - Confidential
2
your London town home?
3
A. I have no idea what this picture
4
was taken. I know what she purports it to be
5
but I'm not going to say that I do.
6
Q. Do the surroundings look like your
7
London town home?
8
A. They are familiar.
9
Q. Do you know who took this picture?
10
A. I do not.
11
Q. Did Jeffrey Epstein take the
12
picture?
13
A. I just testified I don't know who
14
took the picture.
15
Q. So you don't know if Jeffery
16
Epstein took the picture?
17
A. When I tell you I don't know who
18
took the picture, it doesn't mean him -- I
19
don't know who took the picture. You can
20
come up with 50 names, I still do not know
21
who took the picture.
22
Q. Did you observe
go
23
into a room with Virginia alone in your town
24
home?
25
A. I cannot recall. As I have said,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 115 of 465
Page 115
1
G Maxwell - Confidential
2
no.
3
Q. Did
ever tell you
4
that he had sex with Virginia Roberts?
5
A. He did not.
6
Q. Did Jeffrey Epstein ever tell you
7
that
had sex with Virginia
8
Roberts?
9
A. He did not.
10
Q. Did
ever visit -- let
11
me back up for a moment. We talked about
12
Jeffrey's homes, did Jeffrey have a home in
13
the U.S. Virgin islands called Little St.
14
James?
15
A. Yes.
16
Q. Did
ever visit that
17
island -- are you aware of
ever
18
visiting Jeffrey's island?
19
A. I am aware of that, yes.
20
Q. Do you know how many times he
21
visited?
22
A. I do not.
23
Q. Do you know if he visited when
24
Virginia was on the island?
25
A. I do not.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 116 of 465
Page 116
1
G Maxwell - Confidential
2
Q. Were you present on the island when
3
visited?
4
A. Yes.
5
Q. How many times?
6
A. I can only remember once.
7
Q. Were there any girls under the age
8
of 18 on the island during that one visit
9
that you remember that were not family or
10
friends of or daughters of your friends?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. There were no girls on the island
14
at all. No girls, no women, other than the
15
staff who work at the house. Girls meaning,
16
I assume you are asking underage, but there
17
was nobody female outside of the cooks and
18
the cleaners.
19
Q. Did you, as part of your duties in
20
working for Jeffrey, ever arrange for
21
Virginia to have sex with
?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Just for the record, I have never
25
at any time, at anyplace, in any moment ever



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 117 of 465
Page 117
1
G Maxwell - Confidential
2
asked Virginia Roberts or whatever she is
3
called now to have sex with anybody.
4
Q. Did you ever provide Virginia
5
Roberts with an outfit, an outfit of a sexual
6
nature to wear for
?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I think we addressed the outfit
10
issue.
11
Q. I am asking you if you ever
12
provided her with an outfit of a sexual
13
nature to wear for
?
14
A. Categorically no. You did get
15
that, I said categorically no
16
Q. Don't worry I'm paying attention.
17
A. You seemed very distracted in that
18
moment.
19
(Maxwell Exhibit 6, flight logs,
20
marked for identification.)
21
A. Do you mind if I take a break for
22
the bathroom.
23
Q. It's 11:08 and we are going to go
24
off the record now.
25
THE VIDEOGRAPHER: It's now 11:09.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 118 of 465
Page 118
1
G Maxwell - Confidential
2
We are off the record.
3
(Recess.)
4
THE VIDEOGRAPHER: It's now 11:26,
5
we are back on the record and starting
6
disk No. 3.
7
Q. Ms. Maxwell, I think I handed you
8
right before the break, did I hand you the
9
flight logs, they look like this. Did I mark
10
those yet, I thought I did.
11
A. I don't believe I have it.
12
Q. These admittedly are a little
13
difficult to read so what I'm going to
14
provide you with to assist is I have a chart
15
that has the airport codes, because it will
16
have, for example, just for the record
17
reflects that the first page of document
18
, it will have a code in the from line
19
that says PBI, for example, to TEB so I a
20
chart that matches up, just in case you don't
21
understand what those letters mean, PBI
22
meaning Palm Beach, TEB meaning Teterboro,
23
which is New Jersey, but others are more
24
difficult but just for you to be able to
25
understand the logs, I will provide you with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 119 of 465
Page 119
1
G Maxwell - Confidential
2
that.
3
MR. PAGLIUCA: So we are clear, if
4
the witness has personal knowledge of
5
what these are that's fine but I don't
6
know what these are and I don't expect
7
the witness to accept the representation
8
that they are what they are.
9
MS. McCAWLEY: If she can testify
10
to what city it is, she can state that
11
on the record.
12
MR. PAGLIUCA: If she knows what it
13
is, she knows what it is, we are not
14
putting any affirmatively on the record
15
until you ask your questions.
16
Q. So I'm going to ask you and I think
17
we flagged a few of the pages which may
18
direct us a little bit easier but I will do
19
it by Bates number which is at the bottom of
20
the document kind of at the side.
21
The first I will direct your
22
attention to is
23
A. Does it have a tab?
24
Q. It should. Let me make sure.
25
A. Yes it does.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 120 of 465
Page 120
1
G Maxwell - Confidential
2
Q. So I'm directing your attention to
3
the bottom, two lines up from the bottom,
4
there is a flight --
5
MR. PAGLIUCA: Are you on
6
MS. McCAWLEY:
7
Q. So this flight is from, the one I'm
8
looking at, I think it's highlighted on your
9
copy. On the far corner on the date, it says
10
at the top and this would be the
11
and then the
are the two I'm going to
12
direct your attention to.
13
Q. On that first one on the
you
14
will see the column reading PBI in the from
15
column to TEB in the to column and you will
16
see some initials, you will see JE for
17
Jeffrey Epstein, GM for Ghislaine Maxwell,
18
for
and then Virginia?
19
A. I have to object.
20
MR. PAGLIUCA: You don't get to
21
object.
22
Q. She is turning into a lawyer
23
already?
24
A. I would like to.
25
Q. Let me ask the question and if you




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 121 of 465
Page 121
1
G Maxwell - Confidential
2
have an issue -- so with respect to this
3
flight, do you recall being on a flight in
4
the --

going from Palm Beach to
5
Teterboro?
6
A. No, I don't recall any specific
7
flight.
8
Q. Do you recall flying with Virginia
9
on a flight with
and Jeffrey
10
Epstein at any time?
11
A. I don't.
12
Q. How often did you fly on a plane
13
with a 17 year old?
14
MR. PAGLIUCA: Objection to form
15
and foundation.
16
A. I have no idea what you are talking
17
about, other than friends of mine that had
18
kids.
19
Q. Did you regularly fly on Jeffrey's
20
plane with individuals who were under the age
21
of 18?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Can you repeat the question?
25
Q. Did you regularly fly on Jeffrey



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 122 of 465
Page 122
1
G Maxwell - Confidential
2
Epstein's planes with individuals who were
3
under the age of 18?
4
A. I regularly flew on Jeffrey
5
Epstein's airplane but I cannot testify as to
6
flying with people under the age. I don't
7
believe that I did.
8
Q. Why wouldn't you remember flying
9
with a 17 year old?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. How would I know, one, that she is
13
17, how would you know that, how do you know
14
I'm on the plane.
15
Q. Are you saying you are not on this
16
flight, so this is a Palm Beach to Teterboro.
17
This says the JE, GM and Virginia. The GM
18
you are saying is not you?
19
MR. PAGLIUCA: I object to the
20
form. You can answer the question if
21
you know.
22
A. How do you know the GM is me.
23
Q. Is it your testimony that on the
24
flight logs when it represents GM that it is
25
not you flying on the plane?




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 123 of 465
Page 123
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. GM can stand for any level, it
5
could be Georgina, George.
6
Q. Are there any people that flew with
7
Jeffrey Epstein that had the initials GM?
8
A. I don't know.
9
Q. Do you recall flying with Jeffrey
10
Epstein on his plane over 300 times during
11
the period of 1999 to 2005?
12
A. I cannot testify to how many times
13
I was on his plane because that would just be
14
impossible.
15
Q. You were on his plane regularly,
16
would you say?
17
A. I already testified I was on his
18
plane regularly.
19
Q. Is it your testimony and I'm
20
referring now to the line that we were just
21
talking about that you were not on the flight
22
from Palm Beach to Teterboro that lists JE,
23
GM, and Virginia?
24
A. I am not testifying to that. I am
25
just saying that you cannot be sure that is




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 124 of 465
Page 124
1
G Maxwell - Confidential
2
me.
3
Q. So as you sit here today, you don't
4
believe you flew on that plane?
5
A. I'm not saying that. I'm just
6
saying you cannot be sure that's me.
7
Q. Do you have reason to doubt that
8
when it says GM on these flight logs that
9
that represents you?
10
A. I cannot testify to that. I'm just
11
saying it may not be me.
12
Q. In looking at the flight logs and
13
look up, let's move up a couple of lines. If
14
you start at the top, you are going to see
15
JE,
, then JE,

,
16
JE,
, JE, GM, JE, GM, JE, GM,
17
, reposition, JE, GM, JE, GM
18
, JE, GM,
,
19
female,
20
repositioning. JE, GM,

, JE,
21
GM,

, JE, GM,
Virginia,
22
JE, GM,
Virginia, repositioning and then
23
a certification.
24
So is it your testimony in looking
25
at that that you do not believe that the GM




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 125 of 465
Page 125
1
G Maxwell - Confidential
2
represents you?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. I'm not saying that. I'm just
6
saying that you cannot -- I can't sit here
7
and tell you for sure GM is me and I cannot
8
testify remembering being on a flight at that
9
time.
10
Q. You don't remember being on any of
11
these flights with the initial GM?
12
A. I remember being on many flights.
13
I cannot testify that is a flight I am on.
14
Q. Let's go to the next page which is
15
going to be
I want you to look at
16
line -- so the date is at the top, so it's
17
and if you go down, you will see
18
a line that says the
and if you scroll
19
over you will see PBI to TIST, if you look at
20
the airport codes, TIST is going to be
21
representative for the U.S. Virgin Islands
22
and then you will see the list on the plane
23
JE, GM, and Virginia Roberts.
24
Do you recall flying from Palm
25
Beach to the U.S. Virgin Islands with




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 126 of 465
Page 126
1
G Maxwell - Confidential
2
Jeffrey, yourself,
and Virginia
3
Roberts?
4
MR. PAGLIUCA: I object to the form
5
and just so the record is clear, we
6
don't agree with whatever your
7
characterizations are. The document
8
speaks for itself and she can answer
9
based on whatever her personal knowledge
10
is.
11
MS. McCAWLEY: I understand.
12
Q. Do you recall flying with those
13
individuals from Palm Beach to the U.S.
14
Virgin Islands?
15
A. I have no recollection of any
16
individual flight you are pointing out here.
17
You are talking about 2001, how many years
18
ago is that?
19
Q. I'm asking the questions.
20
A. I'm not being difficult. I'm just
21
asking, it's like 14, 15 years ago, it's
22
impossible, I'm sorry.
23
Q. So your testimony is you don't
24
recall flying on that flight with Virginia
25
Roberts?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 127 of 465
Page 127
1
G Maxwell - Confidential
2
A. I cannot testify to that flight.
3
Q. Let's look at the next flight which
4
is on the
from the Virgin Islands back
5
to Palm Beach, JE, Jeffrey Epstein, Ghislaine
6
Maxwell,
, Virginia Roberts, the
7
same individuals on the above flight.
8
A. It doesn't say my name, it has some
9
initials.
10
Q. I understand, the initials GM.
11
Do you recall flying on a plane, on
12
one of Jeffrey's planes from the Virgin
13
Islands to Palm Beach with Virginia Roberts?
14
A. I do not.
15
Q. Was there any other person that
16
flew with Jeffrey Epstein with frequency
17
during that time period in these logs that
18
have the initials GM?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I would have to look at all the
22
flight logs, I have no idea, I flew
23
frequently.
24
Q. Why don't you take a look at the
25
next three pages and see if that refreshes



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 128 of 465
Page 128
1
G Maxwell - Confidential
2
your recollection.
3
MR. PAGLIUCA: You are talking
4
about
5
MS. McCAWLEY: She can pick any
6
couple of pages, those have a lot of the
7
individuals on them so that is a good
8
sampling.
9
MR. PAGLIUCA: So pick any pages
10
you want.
11
Q. Does that refresh your recollection
12
at all as to whether GM represents you or
13
some other individual?
14
A. Again, I can't testify whether that
15
represents me or not, I don't see any other
16
GMs but you have to understand that even if
17
my name is on that record doesn't mean I was
18
on the flight.
19
Q. So are you contesting the accuracy
20
of the flight logs? In other words, you said
21
it doesn't represent you are on the flight so
22
is it your testimony just because a name is
23
listed doesn't mean they were actually on the
24
flight?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 129 of 465
Page 129
1
G Maxwell - Confidential
2
form and foundation.
3
A. I can't testify to what -- these
4
are records that were produced by
5
is on here, so these aren't federally
6
mandated records, so I can't testify to what
7
he produced.
8
Q. I would like you to turn to page,
9
at the bottom, the Bates number is
.
10
And the month is
.
11
A. Okay.
12
Q. If you go down to the number that
13
is
that would be
you're
14
going to see on that line an
which is a
15
and then you
16
will see
which is going to be, I'm going
17
to pronounce it incorrectly,
18
I'm sure I'm not pronouncing that
19
correctly. Then you will see in the list,
20
you will see JE, GM,

,
21
, it looks like --
22
A. I believe it says male.
23
Q. Yes. Then
I
24
believe. Is that GM on this page
25
representative of you?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 130 of 465
Page 130
1
G Maxwell - Confidential
2
A. Well, this would be a flight that I
3
would potentially remember with
4
on it but I don't actually recall going to
5
Russia.
6
Q. Are those your initials, do you
7
recall being on the flight?
8
A. Those are my initials with
9
, I don't recall this flight
10
either, but I would be more likely to if I
11
had a bit more time to study the timing of
12
this.
13
Q. Your testimony is you don't recall
14
flying with
from
to
15
16
A. I don't recall the
to
17
flight. I have definitely flown with
18
.
19
Q. On that same page you will see
20
beneath there, beneath 22 you will see the
21
indication, same as above, same as above,
22
same as above in the column that originally
23
had the initials.
24
A. Uh-huh.
25
Q. And the names.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 131 of 465
Page 131
1
G Maxwell - Confidential
2
A. Uh-huh.
3
Q. Do you recall flying with
4
from
to
5
6
A. I do.
7
Q. So the GM that would be represented
8
in that column would be you?
9
A. I recall going to
with
10
so that is likely to be me.
11
Q. You were on Jeffrey's plane for
12
that trip?
13
A. I believe I was.
14
Q. Do you know who
15
is?
16
A. I do not.
17
Q. I'm going back towards the front
18
which is going to be
please. And
19
you're going to see --
20
A. Hang on I'm not --
21
Q. Take your time.
22
A. Okay.
23
Q. You are going to see in the date
24
column, you will see
and then about
25
halfway down you will see



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 132 of 465
Page 132
1
G Maxwell - Confidential
2
then you will see the
which
3
is the column which is where I want you to
4
start looking at the log and there you're
5
going to see

11
A. Okay.
12
Q. If you look at the column, if you
13
go back up to the top on the
if you look
14
at the column you will see JE, GM,
15
Virginia Roberts and I believe it says
16
sorry I'm not reading that very
17
well.
18
Do you recall flying from, if you
19
see the dates, the
20
Do you recall a trip that went from
21
the United States to
and to the places
22
I just mentioned where Virginia Roberts was
23
on the plane with you?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.








Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 133 of 465
Page 133
1
G Maxwell - Confidential
2
A. I already testified that I don't
3
recall Virginia on any of these flights.
4
Q. I would like to mark, as Maxwell 7,
5
I will put it at the top?
6
(Maxwell Exhibit 7, photo, marked
7
for identification.)
8
MR. PAGLIUCA: Has this document
9
been produced in discovery?
10
MS. McCAWLEY: Yes.
11
MR. PAGLIUCA: Do you have a Bates
12
number?
13
MS. McCAWLEY: This one doesn't.
14
Q. I'm going to ask you --
15
MR. PAGLIUCA: I don't recall
16
seeing this document so I would like to
17
see a Bates number document before we
18
ask questions about it.
19
MS. McCAWLEY: Can you go look for
20
it and I will continue. We will set
21
that aside until we get a Bates number.
22
You may want to leave that log up and
23
set it to the side and we will bounce
24
back to that.
25
Q. Do you recall -- I think earlier



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 134 of 465
Page 134
1
G Maxwell - Confidential
2
you said you visited Jeffrey's island, I
3
think they called it St. Jeffrey or St.
4
James, the U.S. Virgin Island home.
5
A. St. James.
6
Q. Do you recall whether
7
was ever on that island?
8
A. Categorically, definitively,
9
absolutely, without a shadow of a doubt, when
10
I was present or any other time that I am
11
aware of, was
ever on that
12
island, I do not believe he went to that
13
island ever ever, that is an absolute
14
fabrication and an absolute flat out lie.
15
Q. Was
ever at any of Jeffrey
17
Epstein's homes when you present, other than
18
the island I know you said that did not
19
happen, the home in either New York or Palm
20
Beach or New Mexico?
21
A. I do not believe at any time
22
was at any of Jeffrey's
23
homes, I have absolutely no knowledge or
24
otherwise that he was ever there.
25
Q. You don't recall having dinner with




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 135 of 465
Page 135
1
G Maxwell - Confidential
2
him at any of those homes?
3
A. Again, Virginia is absolutely
4
totally lying. This is a subject of
5
defamation about Virginia and the lies she
6
has told and one of lies she told was that
7
President Clinton was on the island where I
8
was present. Absolutely 1000 percent that is
9
a flat out total fabrication and lie.
10
Q. You did fly on planes, Jeffrey
11
Epstein's planes with President Clinton, is
12
that correct?
13
A. I have flown, yes.
14
Q. Would it be fair to say that
15
President Clinton and Jeffrey are friends?
16
A. I wouldn't be able to characterize
17
it like that, no.
18
Q. Are they acquaintances?
19
A. I wouldn't categorize it.
20
Q. He just allowed him to use his
21
plane?
22
A. I couldn't categorize Jeffrey's
23
relationship.
24
Q. When you were on the plane with
25
Jeffrey and President Clinton, did you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 136 of 465
Page 136
1
G Maxwell - Confidential
2
observe Jeffrey and
3
talking?
4
A. I'm sure they did.
5
Q. Did they seem friendly?
6
A. I don't recollect.
7
Q. Was Epstein one of the original
8
people that conceived the
9
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
Q. Do you know?
13
A. I don't have -- I don't know what
14
you are talking about.
15
Q. You don't know what I'm talking
16
about.
17
Did you ever, not at one of houses,
18
but did you ever eat dinner with
19
and Jeffrey Epstein?
20
A. Are you just talking in general
21
anywhere.
22
Q. In general?
23
A. I believe on a plane of this nature
24
we would have had a meal.
25
Q. But not outside of the travel on



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 137 of 465
Page 137
1
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
had a meal on
6
Jeffrey's island is 100 percent false.
7
Q. But he may have had a meal on
8
Jeffrey's plane?
9
A. I'm sure he had a meal on Jeffrey's
10
plane.
11
Q. You do know how many times he flew
12
on Jeffrey's plane?
13
A. I don't.
14
Q. Do you know who
is?
15
A. I do.
16
Q. How do you know him?
17
A. He used to work or still works for
18
19
Q. Did you ever have a relationship
20
with him?
21
A. We are talking about adult
22
consensual relationships, it's off the
23
record.
24
Q. I'm not asking what you did with
25
him, I'm asking if you ever had a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 138 of 465
Page 138
1
G Maxwell - Confidential
2
relationship with him?
3
MR. PAGLIUCA: If you understand
4
the term relationship, certainly you can
5
answer that.
6
A. Define relationship.
7
Q. Somebody that you would have spent
8
time together, either seeing them in a
9
romantic relationship or --
10
A. You need to be, what do you mean by
11
romantic. I was friends with
but you
12
are suggesting something more so I want to be
13
clear what you are actually asking me.
14
Q. You defined it. You said you were
15
friends with him. If that's what you were
16
that's all I need to know.
17
While you were on the trip with
18
, do you recall where you
19
stayed at these locations, in other words,
20
would you leave the jet and stay overnight at
21
a hotel, do you have a recollection of this
22
trip?
23
A. I recollect the trip but if you're
24
asking me where we stayed, you can see it's a
25
very fast paced trip. It was very tiring and



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 139 of 465
Page 139
1
G Maxwell - Confidential
2
I don't recollect where we stayed.
3
Q. Do you recollect if you stayed at
4
the same place
stayed? In
5
other words, if you left the plane to go a
6
hotel did you all go together is your
7
recollection?
8
A. I honestly don't recollect, no.
9
Q. Part of this trip we were just
10
talking about, there is a flight that goes to
11
Thailand, do you remember being in Thailand?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. Are you asking me --
15
Q. On the
trip.
16
A. Are you referencing something?
17
Q. The part that, let me make sure
18
I've got it here. The entry that would be
19
the Thailand, would be the one -- let me make
20
sure I'm correct. I have you on the wrong
21
page, it's actually the page before. It's
22
going to be
And it's going to be the
23
entry on
starting on
and then
24
it goes down to where it has the same as
25
above, to
-- I'm saying



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 140 of 465
Page 140
1
G Maxwell - Confidential
2
3
MR. PAGLIUCA: That's what the
4
document says.
5
Q. I'm not representing the date but
6
there it is. So the last leg of that where
7
it says same as above has, the second to
8
last, I'm sorry on the
10
Do you remember being in Thailand
11
with
?
12
A. I do.
13
Q. Do you remember what the purpose of
14
that trip was?
15
A. I don't.
16
Q. Do you know whether -- do you
17
recall, did you stay the night in Thailand?
18
A. I don't recall.
19
Q. Do you recall why you went to
20
Thailand?
21
A. I don't recall.
22
Q. Who is
?
23
A. She I believe was a stewardess on
24
this flight.
25
Q. Did she perform any massages on the




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 141 of 465
Page 141
1
G Maxwell - Confidential
2
flight?
3
A. I don't recollect any massages on
4
the flight.
5
Q. Do you know who
is?
6
A. It doesn't -- no I don't know who
7
that is, I can't recall.
8
Q. This is not in color, it's a black
9
and white but it has the Bates label on it.
10
Should I take the sticker off the one that
11
has -- I don't know if you want to swap it.
12
MR. PAGLIUCA: Let the record
13
reflect I am replacing this on the black
14
and white copy of this exhibit with
15

.
16
Q. So, we were talking earlier, we
17
were looking at the flight logs and we were
18
talking about a trip and let me just get you
19
back to the page.













Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 142 of 465
Page 142
1
G Maxwell - Confidential
2
Q. Can I direct your attention to the
3
picture, please.
4
A. Of course.
5
Q. Can you tell me who is in this
6
picture, who is pictured here, and for the
7
court reporter's benefit, can you go from the
8
left of the picture to the right of the
9
picture, to the extent you can identify the
10
individuals?
11
A. Sure. I cannot identify the person
12
on the left, I cannot identify the person
13
next left. I can identify Jeffrey Epstein.
14
I cannot identify the next person to his
15
right and the next person in the picture is
16
myself.
17
Q. Is the individual all the way to
18
the left at the beginning of the picture,
19
does that resemble
. You might
20
want to look at the color version if that
21
helps you at all, I know it's not the marked
22
one. I don't if that's easier to see, they
23
are both dark.
24
A. That does not look like
25
at all.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 143 of 465
Page 143
1
G Maxwell - Confidential
2
Q. Do you recall --
3
MR. PAGLIUCA: Let's mark this then
4
as deposition Exhibit 8 since we are
5
referring to it and then you can give us
6
copies as well.
7
MS. MENNINGER: It's different
8
because it has other people in this
9
color photo.
10
(Maxwell Exhibit 8, photo, marked
11
for identification.)
12
Q. Do you recall who took this
13
photograph?
14
A. I do not.
15
Q. Do you recall this photograph being
16
taken by Virginia?
17
A. First of all, I don't know where we
18
are.
19
Q. So you don't recognize the
20
building?
21
A. I don't recognize the building and
22
I don't recognize -- the only two people I
23
recognize in the picture are Jeffrey and
24
myself.
25
Q. Does this like look a picture of a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 144 of 465
Page 144
1
G Maxwell - Confidential
2
building that you would have seen when you
3
were on the trip in Europe?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I can't possibly answer that.
7
Q. Do you recall Virginia ever taking
8
pictures?
9
A. I barely recall Virginia, period.
10
Q. Do you recall her ever taking
11
pictures?
12
A. No, I don't.
13
Q. I'm going to direct your attention,
14
still within the flight logs to -- starting
15
on the next page from where you just were
16
which is going to be
And the date at
17
the top says
you will see
and I'm
18
directing your attention down towards the
19
middle to the bottom where you will see the
20
numbers
21
A. Uh-huh.
22
Q. And we've got actually I'm going to
23
direct your attention to the one that starts
24
with




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 145 of 465
Page 145
1
G Maxwell - Confidential
2
and in the line, the remarks line you will
3
see JE, GM,




?
5
MR. PAGLIUCA: Are you reading the
6
29th, is that what you're reading?
7
MS. McCAWLEY: I'm reading the
8
29th, yes.
9
Q. Below that you will see JE, GM,
10
11
12
Do you see that?
13
A. I do.
14
Q. Do you recall a trip from Teterboro
15
to Santa Fe and Santa Fe back to Palm Beach
16
with these individuals?
17
A. I don't.
18
Q. Do you recall being on a plane with
19
and Virginia Roberts?
20
A. I don't.
21
Q. Do you recall ever witnessing any
22
sexual interaction on one of Jeffrey's planes
23
with any of these individuals?
24
A. I do not, absolutely not.
25
Q. Did Jeffrey have a fold out bed on




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 146 of 465
Page 146
1
G Maxwell - Confidential
2
one of his planes?
3
A. There was a bed on one of his
4
planes that folded out, yes.
5
Q. Do you recall whether with respect
6
to this being in Santa Fe, do you recall
7
whether you were there for some form of a
8
party?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I don't recall the trip at all and
12
this looks like a total work trip, not a
13
party trip.
14
Q. What would be the difference
15
between a work trip and a party trip?
16
A. Just that I would be on trips for
17
work and I believe that this looks like,
18
looks like it's one of the -- probably one of
19
the designers and the time would meet with a
20
trip to decorate the house, just the timing
21
of it.
22
Q. So would Virginia be brought on
23
trips that were for the purpose of work and
24
decorating the house?
25
A. Like I said, I never worked with




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 147 of 465
Page 147
1
G Maxwell - Confidential
2
her but you would have to ask Jeffrey what he
3
brought her on the trip for.
4
Q. But she would travel with him when
5
there was a work trip like this?
6
A. I can't -- I'm seeing that she is
7
on this flight but I have no idea what she is
8
doing, he invited her, it would not be my
9
job.
10
Q. What about Nadia Bjorlin, would she
11
regularly travel with Jeffrey on flights?
12
A. I have no idea, you would have to
13
look through the flight logs. I have no
14
idea.
15
Q. Your recollection is -- what is
16
your recollection, do you recollect Nadia
17
traveling often on flights with Jeffrey?
18
A. Absolutely not. No, not at all. I
19
don't recollect her actually on the flight at
20
all.
21
Q. I think you can set that aside for
22
the moment.
23
(Maxwell Exhibit 9, message pad
24
pages, marked for identification.)
25
Q. We will mark as Exhibit 9 these



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 148 of 465
Page 148
1
G Maxwell - Confidential
2
excerpts from -- we will identify what they
3
are but from the message pads.
4
Did you want to correct anything?
5
A. I want to make an addendum.
6
Would you mind rereading the last
7
question back to me?
8
(Record read.)
9
A. I also just want to say that at
10
this point I cannot recollect flying to
11
parties. Jeffrey went for work so -- was
12
this in Santa Fe, this flight as well.
13
Q. The flight we were looking at, yes
14
but it was to Santa Fe --
15
A. I don't recall going to any parties
16
in Santa Fe at any time but certainly flying
17
to Santa Fe for a party seems highly
18
improbable.
19
Q. So I'm going to direct your
20
attention to the document that I set before
21
you which is Bates number
and it
22
has different Bates numbers because it's a
23
smaller version of the larger production.
24
These are the pages I will be asking about.
25
In the time that you were working



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 149 of 465
Page 149
1
G Maxwell - Confidential
2
with Jeffrey in Palm Beach, do you recall a
3
process for taking, anybody at the house
4
taking messages when incoming phone calls
5
came in?
6
A. You are supposed to take a message
7
and receive the message and write the message
8
down. Who was the message was for, what time
9
it was taken and who took it and what the
10
message was, obviously.
11
Q. Does what's in front of you look
12
familiar with respect to the message pads
13
that you would have used at the house?
14
A. It is familiar.
15
Q. I'm going to direct your attention
16
to the second page of it?
17
MR. PAGLIUCA: These all have SAO
18
numbers on them or Bates ranges and I
19
don't see any of your Bates ranges on
20
these. I know you have produced message
21
pads but those have your Bates range
22
numbers on them and I'm wondering if
23
these are different documents.
24
MS. McCAWLEY: It's the same, just
25
ours have the Bates underneath them.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 150 of 465
Page 150
1
G Maxwell - Confidential
2
These were produced as part of the rule
3
26 discovery. We can get the additional
4
Bates if you want.
5
Q. The one I'm asking about first is
6
the
. You can look at that and then
7
I will identify the Bates number referenced
8
in this case.
9
I want to direct your attention to
10
the top right-hand corner just so I have an
11
understanding of how these messages were
12
taken. So I see that it says at the top it
13
says in the for line it says Ms. Maxwell and
14
the date of
and then I see under the
15
M line it looks like
or
16
something like that, a phone number and a
17
message saying returning your call and on the
18
bottom it looks like
19
Explain to me, is this -- does this
20
represent
taking down a message for you
21
from
is that how these work?
22
MR. PAGLIUCA: Objection to the
23
form and foundation. Go ahead.
24
Q. My question is, I'm trying to
25
understand how the messages were taken.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 151 of 465
Page 151
1
G Maxwell - Confidential
2
Looking at this message pad, where it says
3
signed
can you tell me who
was?
4
A. I cannot.
5
Q. You do not know.
6
Typically when these messages were
7
taken in your practice when you were there,
8
would the individual who took the message
9
write their name on the message?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I don't recollect, you can ask who
13
wrote it so you can find out who it was.
14
Q. Do you know who
is?
15
A. I don't.
16
Q. I'm going to direct your
17
attention -- do we have a Bates number for
18
that?
19
MR. EDWARDS:
20
Q. Giuffre
for that one.
21
I will direct your attention to the
22
first page which has the
on it.
23
A. Okay.
24
Q. Now at the top of that document, on
25
the right-hand side, the message that reads



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 152 of 465
Page 152
1
G Maxwell - Confidential
2
for JE, date
, message
3
and then it's signed GM.
4
Is that your signature?
5
A. That's not my handwriting.
6
Q. Would other people take a message,
7
how did this process work, is there someone
8
else in the house with the initials GM?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I cannot answer that. It's not my
12
handwriting.
13
Q. I'm trying to understand how this
14
gets there. If you took a message and didn't
15
write it down, would someone else record that
16
message for you?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. All I can tell you, this is not my
20
handwriting so I cannot -- I have no idea
21
what that is.
22
Q. Was the practice that, what was the
23
practice when someone answered the phone with
24
these message pads, what were they supposed
25
to do?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 153 of 465
Page 153
1
G Maxwell - Confidential
2
A. They were supposed to take a
3
message and the time and date and give the
4
message.
5
Q. Were they supposed to indicate who
6
took the message?
7
A. They were but it wasn't -- I don't
8
really recall the actual process. I can see
9
from here it looks like you were supposed to
10
but that's not my handwriting so I can't say
11
what that was.
12
Q. Do you know who
is?
13
A. No, I don't.
14
Q. Do you know whether
15
was under the age of 18?
16
A. I just testified I couldn't
17
remember who she was so it would be difficult
18
to know how old she was.
19
Q. Do you know if she was coming to
20
the house to provide massages?
21
A. I don't remember who she is at all,
22
so no.
23
Q. And then I would like to direct
24
your attention to the message right
25
underneath it. Which says JE,
,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 154 of 465
Page 154
1
G Maxwell - Confidential
2
and has a phone number and the message says,
3
wants to know if she should bring her friend
4
tonight.
5
What is that message referring to?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I can't possibly know.
9
Q. Did individuals at the house take
10
messages for underage girls to come over and
11
bring friends for the purpose of providing
12
massages?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. How would I possibly know what you
16
are talking about.
17
Q. Did you record messages at the
18
house?
19
A. It's not my job.
20
Q. You did from time to time record
21
messages?
22
A. Hardly ever.
23
Q. But you did from time to time do
24
it?
25
A. I'm just saying I hardly ever took



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 155 of 465
Page 155
1
G Maxwell - Confidential
2
messages, very, very, very, very
3
infrequently.
4
Q. Do you know if
brought her
5
friend
over on that night?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. One, I don't know what this message
9
is, I don't know if I was in Palm Beach, I
10
don't know who
is, I don't know who
11
is and I don't know what this message
12
is referring to.
13
Q. So on January 2nd of 2003, were you
14
in Palm Beach?
15
A. I don't know.
16
Q. Where would you have been other
17
than Palm Beach at the time?
18
A. I could have been anywhere.
19
Q. Where did you typically live?
20
A. What are you asking me?
21
Q. So for example, in 2003, where was
22
your primary residence, was it wherever
23
Jeffrey was living and staying or was it
24
independent of that?
25
A. What was the date again.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 156 of 465
Page 156
1
G Maxwell - Confidential
2
Q. In 2003?
3
A. The end of 2003?
4
Q. January, the beginning.
5
A. I don't know, I could have been
6
anywhere, Jeffrey and I were leading almost
7
separate lives by then.
8
Q. If you were at the house that day,
9
did you recall seeing anybody by the name of
10
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I don't know if I was at the house,
14
so I can't testify to that.
15
Q. Let's flip back to the next page,
16
the one we were on before the
the
17
message towards the bottom that says, for
18
Jeffrey, message of Ghislaine. And it says,
19
Would it be helpful to have and then redacted
20
come to Palm Beach today to stay here and
21
help train new staff with Ghislaine. Who
22
were you referring to in that message; do you
23
remember?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 157 of 465
Page 157
1
G Maxwell - Confidential
2
Q. The question is, do you recall this
3
message?
4
A. I do not recall this message.
5
Q. Do you recall training a female
6
under the age of 18 at Jeffrey's home?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I never trained a female under the
10
age of 18 at Jeffrey's home.
11
Q. Did you ever say it would be
12
helpful to have a female under the age of 18
13
come to Palm Beach today to stay here and
14
help train new staff with Ghislaine?
15
A. I never asked anyone under the age
16
of 18 come to help train new staff.
17
Q. I'm going to flip to the next page
18
which is
.
19
A. By the way, that is not my
20
handwriting and it's not dated and I couldn't
21
possibly tell you who that is.
22
Did you hear that?
23
Q. You got your testimony on the
24
record.
25




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 158 of 465
Page 158
1
G Maxwell - Confidential
2
A. Yes.
3
MR. EDWARDS: Giuffre
4
Q. I'm going to direct your attention
5
to the top right-hand corner, for Mr.
6
Epstein,
, message
a phone
7
number and called.
8
Do you know who
is?
9
A. I don't.
10
Q. Do you know that
was 15 at
11
the time she left this message?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I don't know who
is.
15
Q. And then I'm going to direct your
16
attention to the bottom left which is a
17
message JE message of
and the
18
message says, He just did a good one, 18
19
years, she spoke to me and said I love
20
Jeffrey.
21
Was
referring to sex with
22
an 18 year old in that message?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. How could I know what
is



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 159 of 465
Page 159
1
G Maxwell - Confidential
2
referring to.
3
Q. Do you know if
had sex
4
with an 18 year old that he referenced to
5
Jeffrey Epstein?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. How could I possibly know.
9
Q. Did Jeffrey Epstein or
10
ever tell you that
had sex with an
11
18 year old?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I have no idea what you are talking
15
about.
16
Q. Did they ever tell you that?
17
A. I have no recollection of ever
18
hearing such a ridiculous thing.
19
Q. I will turn to the next page which
20
is SAO 2841?
21
MS. MENNINGER: Do you have the
22
Bates number?
23
Q. The bottom right-hand corner, Mr.
24
Epstein, the date
, Ms. Maxwell, it
25
says,
it says, quote,
is



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 160 of 465
Page 160
1
G Maxwell - Confidential
2
available on Tuesday, no one for tomorrow.
3
Is this a message you took?
4
A. It's not my handwriting and I don't
5
know who R is.
6
Q. So when it says Ms. Maxwell in the
7
line there, is that you calling for Mr.
8
Epstein?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I didn't write it, I don't know
12
when this message was taken. I don't even
13
know what it's referring to and I don't know
14
what my name is doing on that message pad.
15
Q. I know you said you only took them
16
a few times. Do you have a recollection of
17
taking messages of females who would call the
18
house to indicate whether or not they were
19
coming over?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. Give me a date range.
23
Q. On 7/9/04.
24
A. How would I know if I'm in Palm
25
Beach, most likely not.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 161 of 465
Page 161
1
G Maxwell - Confidential
2
Q. I'm asking if you have a
3
recollection of taking messages for girls who
4
would call the house --
5
A. Girls.
6
Q. Females, who would call the
7
house --
8
A. Over the age of 18.
9
Q.
is 15.
10
A. I don't know who
is, so I
11
can't testify anything to
12
Q. Your name is on the message.
13
A. I didn't put it there and I don't
14
know what it's doing there.
15
Q. So your testimony is you didn't
16
take this message?
17
A. I obviously didn't take the
18
message, it's signed by somebody R, it's not
19
my handwriting. We don't know if I'm in Palm
20
Beach.
21
Q. Did you arrange for
to have
22
his friend
come over on Tuesday of
23
this week?
24
A. I don't know who
is so it
25
would be hard for me to arrange anything with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 162 of 465
Page 162
1
G Maxwell - Confidential
2
someone I don't know.
3
Q. Why is your name reflected on this
4
message pad?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I have no idea. You would have to
8
ask whoever took the message.
9
Q. Did you, in the course of your
10
work, regularly take messages for Jeffrey
11
Epstein?
12
A. I already testified I hardly ever
13
did.
14
Q. Would you, in the course of your
15
work, regularly set up appointments for
16
females to come over and give massages for
17
Jeffrey Epstein?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. Can you specify, females, you mean
21
adults over the age of 18.
22
Q. Did you regularly set up for
23
Jeffery adults over the age of 18 to come for
24
massages?
25
A. I didn't regularly do that, no.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 163 of 465
Page 163
1
G Maxwell - Confidential
2
Q. Would you take messages with
3
respect to females over the age of 18 to come
4
over for a massage?
5
A. I already testified I hardly ever
6
did take messages.
7
Q. But would you?
8
A. I already testified, I hardly
9
ever --
10
Q. I know hardly ever, but did you?
11
A. Over the course of time it is
12
possible I may have taken a couple, I have no
13
recollection. I hardly ever did and I did so
14
irregularly that it would hard for me to
15
pinpoint.
16
Q. Did you ever take a message for a
17
female under the age of 18 to come over for a
18
massage or for any other reason to be with
19
Jeffrey Epstein?
20
MR. PAGLIUCA: Object to the form
21
and foundation.
22
A. I hardly ever took a message. I
23
have absolutely no way of knowing, maybe one
24
of my friends' daughters called to say they
25
were coming to visit me. I have never taken



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 164 of 465
Page 164
1
G Maxwell - Confidential
2
messages, I don't know about how I would
3
possibly know if somebody I spoke to, one or
4
two times I took a message is, how old they
5
would be but I have never taken a message
6
where I was aware of anything being under the
7
age of 18 and I probably took it so
8
infrequently, it would be impossible.
9
Q. Can you turn to
, it
10
should be the next page.
11
A. Uh-huh.
12
Q. Do you see at the top, it says, for
13
Mr. J. 11/8/04 and then the name is
14
redacted. It says, I have a female for him.
15
Why would a minor be calling
16
Jeffrey to say they have a female for him?
17
Do you know?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. First of all, I don't know that's a
21
minor, I don't know who took the message.
22
Q. I will represent to you these are
23
police reports and minor's names have to be
24
redacted for privacy purposes?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 165 of 465
Page 165
1
G Maxwell - Confidential
2
form and foundation.
3
Q. Do you know why a minor child would
4
be calling Jeffrey and leaving a message to
5
say, quote, I have a female for him?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I can't testify anything about this
9
message, I don't know anything about it.
10
Q. I'm going to direct your attention
11
to the next page
. If you look at
12
the bottom left, you are going to see a
13
message for Jeffrey, from
, it
14
says she doesn't have a number and left a
15
message that she called.
16
Do you know who
is?
17
A. I do not.
18
Q. Do you know that
was
19
13 at the time she placed this call to
20
Jeffrey?
21
A. I don't know who
is.
22
Q. Would Jeffrey regularly have 13
23
year olds call and leave messages?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 166 of 465
Page 166
1
G Maxwell - Confidential
2
A. How would I possibly, these were
3
messages taken when I was not at the house
4
and I have no idea who they are nor how old
5
they are nor anything.
6
Q. How do you know you weren't at the
7
house on this day?
8
A. I was hardly at the house in 2005.
9
Q. So you could have been there, you
10
just don't know?
11
A. In the five days I might have been
12
there in 2005, I suppose it's possible but
13
it's unlikely.
14
MR. PAGLIUCA: Do you know why this
15
isn't redacted if you are representing
16
all the names of people who are underage
17
have been redacted from these records.
18
MS. McCAWLEY: I think it was -- my
19
assumption is it was a miss by the
20
police department.
21
Q. I will direct your attention to
22
so you will skip a page and go back,
23
it's the final page in the message pads and
24
you will see on the top left for Jeffrey, on
25
6/1/2005 from
with a phone



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 167 of 465
Page 167
1
G Maxwell - Confidential
2
number. It says, quote, He has a teacher for
3
you to teach you how to speak Russian. She
4
is two times eight years old. Not blond.
5
Lessons are free and you can have your first
6
today if you call.
7
Do you know whether
8
sent a Russian girl that was 16 years old
9
over to Jeffrey Epstein's home?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I do not know.
13
Q. Did you ever observe a Russian girl
14
that was 16 years old come to Jeffrey
15
Epstein's home?
16
A. I am not aware of any 16 year old
17
Russian girl that I can recall in Jeffrey
18
Epstein's home.
19
Q. Do you know whether Jeffrey Epstein
20
had sex with a 16 year old Russian girl?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. I do not know.
24
THE VIDEOGRAPHER: It's 12:25.
25
This will be the end of disk 3, we are



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 168 of 465
Page 168
1
G Maxwell - Confidential
2
off the record.
3
(Recess.)
4
A F T E R N O O N S E S S I O N
5
(Time noted: 1:21 p.m.)
6
G H I S L A I N E M A X W E L L,
7
resumed and testified as follows:
8
EXAMINATION BY (Cont'd.)
9
MS. McCAWLEY:
10
THE VIDEOGRAPHER: It's now 1:21,
11
we're starting disk No. 4. We are back
12
on the record.
13
Q. Ms. Maxwell, before the break, we
14
were talking about and I think it's one of
15
the exhibits that's marked in front of you,
16
I'm not sure of the number, but the police
17
report that I showed you earlier today.
18
Now that you have knowledge of the
19
police report and the criminal investigation
20
with respect to Jeffrey Epstein, do you
21
believe that Jeffrey Epstein abused any minor
22
children?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Can you repeat the question please



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 169 of 465
Page 169
1
G Maxwell - Confidential
2
and break it down so it's more
3
understandable.
4
Q. Now that you have the police report
5
that I showed you this morning that you had
6
an opportunity to look at.
7
A. You gave it to me, I did not look
8
at it.
9
Q. The questions that I asked you
10
about the police report -- you are aware
11
there is a police report?
12
A. I am aware there is a police
13
report.
14
Q. You are aware there was a criminal
15
investigation of Jeffrey Epstein?
16
A. I am aware that there was that.
17
Q. Now that you are aware of those two
18
things and having talked to Jeffrey Epstein,
19
do you believe Jeffrey Epstein sexually
20
abused minors?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. Can you reask the second part of
24
that question please.
25
Q. Sure. The two documents we were



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 170 of 465
Page 170
1
G Maxwell - Confidential
2
talking about, the document and the
3
investigation, you said you are aware of and
4
after having talked to Jeffrey Epstein, do
5
you believe Jeffrey Epstein sexually abused
6
minors?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. What do you mean I talked to
10
Jeffrey, you need to break the question down
11
further.
12
Q. So you have the police report.
13
A. I do.
14
Q. And you are aware of the criminal
15
investigation?
16
A. I am.
17
Q. Let's take those two things. After
18
knowing those two things, do you believe that
19
Jeffrey Epstein abused minor children?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. Can you explain what you mean by
23
the question actually.
24
Q. I think the question speaks for
25
itself. I will try again. I will say it one



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 171 of 465
Page 171
1
G Maxwell - Confidential
2
more time because I want you to be able to
3
understand it.
4
Knowing that you have the police
5
report here and knowing about the criminal
6
investigation, do you believe that Jeffrey
7
Epstein sexually abused minors?
8
MR. PAGLIUCA: Same objection.
9
A. I know what you put in front of me
10
and I know what I read.
11
Q. I'm asking what you believe, do you
12
believe Jeffrey Epstein sexually abused
13
minors?
14
A. I can only tell you what I read and
15
what you showed me.
16
Q. I'm asking what you believe, from
17
your own belief, do you believe that Jeffrey
18
Epstein abused minors?
19
A. I can only go from what I know
20
personally and what I know personally about
21
what Virginia's lies talked about. She is
22
the only person I know that actually claimed
23
that. And I can say with certitude that
24
everything Virginia said was a lie.
25
Q. You are aware Jeffrey Epstein was



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 172 of 465
Page 172
1
G Maxwell - Confidential
2
sentenced for sexual abuse, are you aware of
3
that?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
Q. Are you aware that Jeffrey Epstein
7
served time for sexual abuse of a minor?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I don't believe that's what he was
11
sentenced for, actually.
12
Q. So you don't know that Jeffrey
13
Epstein served time for sexually abusing a
14
minor?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I don't believe that's what he was
18
sentenced for.
19
Q. Do you know that Jeffrey Epstein
20
was convicted for procuring a minor for
21
prostitution?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. I don't know exactly what he was
25
convicted of. I don't know that he was



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 173 of 465
Page 173
1
G Maxwell - Confidential
2
convicted. I know he spent time in jail.
3
Q. Do you know that he spent time in
4
jail related to an issue with a minor child?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I did not know that.
8
Q. What did you think he was spending
9
time in jail for?
10
A. I only know he went to jail for --
11
it was alleged that he hired -- had an
12
underage prostitute.
13
Q. So knowing that, do you believe
14
that Jeffrey Epstein sexually abused minors?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I can only tell you what he went to
18
jail for.
19
Q. I'm asking what you believe. I'm
20
not asking what he went to jail for. I'm
21
asking for your belief.
22
A. I cannot testify to what I believe.
23
I can only say what I have seen in the
24
reports and I know he went to jail.
25
Q. You can testify to what you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 174 of 465
Page 174
1
G Maxwell - Confidential
2
believe. Do you believe --
3
A. I can only testify --
4
Q. Let me finish the question so the
5
record is clear.
6
Do you believe Jeffrey Epstein
7
sexually abused minors?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
Q. You can answer.
11
A. I can only testify to what I know.
12
I know that Virginia is a liar and I know
13
what she testified is a lie. So I can only
14
testify to what I know to be a falsehood and
15
half those falsehoods are enormous and so I
16
can only categorically deny everything she
17
has said and that is the only thing I can
18
talk about because I have no knowledge of
19
anything else.
20
Q. I'm not asking about Virginia. I'm
21
asking whether you believe that Jeffrey
22
Epstein sexually abused minors?
23
A. Again, I repeat, I can only go on
24
what I know and what I know is a falsehood
25
based on what Virginia said.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 175 of 465
Page 175
1
G Maxwell - Confidential
2
Q. Do you believe Jeffrey Epstein
3
sexually abused minors?
4
A. Again, I repeat, Virginia is a liar
5
and based on Virginia's stories, that is
6
what -- she lied and I can only then talk
7
about what you've showed me in the police
8
reports and I know he went to jail.
9
Q. Do you believe that Jeffrey Epstein
10
sexually abused minors? I'm asking about
11
your belief.
12
A. Again, I just repeat, I can only
13
go -- my belief is Virginia is a liar.
14
Q. What is that belief?
15
A. She is an absolute liar and
16
everything she said is a lie and therefore,
17
everything that stems from that is a lie.
18
Q. So do you believe that Jeffrey
19
Epstein sexually abused minors?
20
A. Again -- can we move on from here?
21
Q. No. You are going to answer the
22
question.
23
A. I have already.
24
Q. No, you haven't.
25
A. I have.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 176 of 465
Page 176
1
G Maxwell - Confidential
2
Q. Do you believe Jeffrey Epstein
3
sexually abused minors?
4
A. Again, I repeat, the only person I
5
know who has talked about these things that I
6
have personal -- was personally present, was
7
Virginia and I can only talk to Virginia and
8
she is a liar.
9
Q. Setting aside Virginia. Take her
10
out of the picture. It's my question.
11
A. We are here today because of
12
Virginia and her lies because this is a
13
defamation suit.
14
Q. Setting aside Virginia, do you
15
believe Jeffrey Epstein sexually abused
16
minors?
17
A. I cannot set aside Virginia because
18
that's why we are here and this is the only
19
reason I am sitting here in this room and I
20
will not set her aside and I cannot comment
21
about anything else except her because she is
22
the only person I actually know about.
23
Q. Are you refusing to answer that
24
question?
25
A. I am not refusing the question. I



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 177 of 465
Page 177
1
G Maxwell - Confidential
2
can only testify about Virginia who is an
3
absolute total liar and you all know she is.
4
She lied about her age, you know she lied
5
about absolutely everything. So I can only
6
go on what I know as a liar and she is a
7
liar, an exaggerator, a fantasist and
8
absolutely true terrible person.
9
Q. I want you to listen very
10
carefully. I am asking you to set aside
11
Virginia.
12
A. I can't set aside Virginia.
13
Q. I am asking you to do that for
14
purposes of this question.
15
MR. PAGLIUCA: She doesn't have to.
16
MS. McCAWLEY: She can refuse to
17
answer the question.
18
A. I'm not refusing to answer the
19
question.
20
Q. You are refusing.
21
My question has nothing to do with
22
Virginia. Let me make the record here. My
23
question has nothing to do with Virginia. I
24
want it to be clear for the court. My
25
question has nothing to do with Virginia.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 178 of 465
Page 178
1
G Maxwell - Confidential
2
What I'm asking you is whether you
3
believe Jeffrey Epstein abused minors?
4
MR. PAGLIUCA: I object to the form
5
and you made your record, she answered
6
the question. A fair reading of her
7
answer is she doesn't have a belief
8
because she doesn't have any personal
9
knowledge.
10
MS. McCAWLEY: Now you are
11
testifying for the witness. Let her
12
answer the question.
13
MR. PAGLIUCA: It's a fair answer
14
to the question.
15
A. Again, I testified my only personal
16
knowledge concerns Virginia and everything
17
Virginia has said is an absolute lie, which
18
is why we are here in this room. If you are
19
asking me to testify about things I have no
20
knowledge of other than the police report
21
that you showed me, I am not in a position to
22
make a statement based on that because you
23
are asking me to speculate and I cannot
24
speculate.
25
Q. I'm asking you about your belief.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 179 of 465
Page 179
1
G Maxwell - Confidential
2
I'm not asking you to speculate at all. I'm
3
asking what you believe.
4
A. You are asking me to speculate and
5
I won't speculate.
6
Q. I'm not asking you to speculate.
7
I'm asking what you believe.
8
MR. PAGLIUCA: She answered the
9
question and we can move on.
10
MS. McCAWLEY: She hasn't answered
11
the question.
12
MR. PAGLIUCA: We are not going to
13
engage in this debate. She answered the
14
question. If you want to mark it and
15
move to compel an answer to the
16
question, have at it. Okay.
17
Q. Ms. Maxwell, is it your belief that
18
Jeffrey Epstein interacted sexually with
19
minors?
20
A. Again, you are asking me the same
21
type of question exactly but with different
22
language. Again, my only knowledge of
23
somebody who claims these things that I have
24
personal knowledge of is Virginia. Virginia
25
is an absolute liar and everything she has



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 180 of 465
Page 180
1
G Maxwell - Confidential
2
said is a lie. Therefore, based on those
3
lies I cannot speculate on what anybody else
4
did or didn't do because if Virginia is the
5
example of what that story is and everything
6
she said is false, so everything that leads
7
from that is false.
8
Q. So the 30 other minor children in
9
the police report are also telling lies about
10
being sexually abused during massages with
11
Mr. Epstein?
12
MR. PAGLIUCA: Objection to the
13
form and foundation. Counsel, can you
14
show me in these police reports who the
15
30 minors are?
16
MS. McCAWLEY: I'm asking my
17
question.
18
MR. PAGLIUCA: You are making a
19
representation about numbers, you are
20
making a representation on the record
21
about what people said or didn't say.
22
We have no knowledge about that. These
23
are all redacted records so these are
24
bad questions. They don't lead to any
25
admissible evidence. It is only being



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 181 of 465
Page 181
1
G Maxwell - Confidential
2
propounded to the witness to harass her.
3
So we are done with these questions.
4
MS. McCAWLEY: Are you done?
5
MR. PAGLIUCA: Yes.
6
Q. My question is, are you aware that
7
Jeffrey Epstein was convicted of having
8
relations with a minor child?
9
MR. PAGLIUCA: She answered that
10
question already.
11
MS. McCAWLEY: I'm getting to my
12
next question.
13
MR. PAGLIUCA: Ask your next
14
question. Don't keep asking the same
15
question.
16
MS. McCAWLEY: You are now
17
shouting, I want the record to reflect
18
that you are interrupting the
19
deposition. I ask you to calm down,
20
take a deep breath and please let me ask
21
my questions.
22
MR. PAGLIUCA: Your behavior is
23
inappropriate.
24
Q. I will ask you again.
25
Do you believe that Jeffrey Epstein



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 182 of 465
Page 182
1
G Maxwell - Confidential
2
interacted sexually with minors?
3
A. Again, I go back to this, my only
4
actual knowledge is with Virginia and
5
Virginia is a liar, so I can only talk to
6
what Virginia's story and as I said before
7
and there are so many examples, I mean
8
thousands of examples of her lies, that that
9
is the only thing I can talk to.
10
Q. Based on that you do not believe
11
that Jeffrey Epstein sexually abused minors?
12
A. Again, as I said, I'm only talking
13
to what I know, I can only talk to Virginia.
14
Q. So is it your belief that Jeffrey
15
Epstein did not sexually abuse minors?
16
A. Again, I can only talk to what I
17
know and I know that Virginia is a liar and
18
that what she said is a lie. So I can only
19
testify to what she accused and you guys put
20
in the press for salacious purposes and
21
whatever terrible, inappropriate, unethical
22
and terrible reasons you chose to do that
23
about me and I can testify those are all
24
lies.
25
Q. Do you know whether Jeffrey Epstein



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 183 of 465
Page 183
1
G Maxwell - Confidential
2
sexually abused any minor children?
3
A. Again, I only know 1000 percent
4
that Virginia is a liar. I can only talk to
5
Virginia, her lies and your inappropriate,
6
unethical, really unattractive, terrible use
7
of her and the way that you have abused the
8
system, used the press for purposes that are
9
unethical, inappropriate and appalling.
10
Q. Do you believe that Jeffrey Epstein
11
used massages to lure minors to have sex with
12
him?
13
A. Again, that is Virginia's
14
testimony, which is a lie.
15
Q. But do you believe that?
16
A. Again, I refer back to Virginia.
17
Q. I'm asking whether you believe it
18
or not?
19
A. I can only go with what I know and
20
I know Virginia is a liar and therefore
21
that's a lie.
22
Q. So you don't believe that?
23
A. I said, I only know that Virginia
24
is lying.
25
Q. Are you aware that Jeffrey Epstein



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 184 of 465
Page 184
1
G Maxwell - Confidential
2
is a registered sex offender?
3
A. I am.
4
Q. Are you aware that Jeffrey Epstein
5
paid considerable amounts of money to settle
6
lawsuits with the minor children that he had
7
sexual contact with?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I have no knowledge of those
11
issues.
12
Q. Why did you continue to maintain
13
contact with Jeffrey Epstein after he pled
14
guilty?
15
A. I'm a very loyal person and Jeffrey
16
was very good to me when my father passed
17
away and I believe that you need to be a good
18
friend in people's hour of need and I felt
19
that it was a very thoughtful, nice thing for
20
me to do to help in very limited fashion
21
which was helping if he had any issue with
22
his homes, in terms of the staffing issues.
23
It was very, very minor but I felt it was
24
thoughtful in somebody's hour of need.
25
Q. Did he continue to pay you during



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 185 of 465
Page 185
1
G Maxwell - Confidential
2
that time period?
3
A. I was paid a little.
4
Q. You were paid?
5
A. Yes.
6
Q. When you say a little, what you did
7
mean by that?
8
A. I don't recall exactly the amount.
9
Q. So in 2009 when you left him, what
10
were you being paid?
11
A. I just told you, I don't recall.
12
Q. Were you being paid $100,000?
13
A. I just don't you I don't recall.
14
Q. Were you paid over a million
15
dollars?
16
A. I think I would remember over a
17
million dollars.
18
Q. So it was under a million dollars?
19
A. It was under a million dollars.
20
Q. Was it over $500,000?
21
A. I just told you, it was under 500,
22
it was an amount of money less than $500,000,
23
less than a million dollars and I did it out
24
of thoughtfulness and consideration for
25
somebody who was in trouble.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 186 of 465
Page 186
1
G Maxwell - Confidential
2
Q. Did you have an attorney to consult
3
with during the criminal investigation of
4
Jeffrey Epstein?
5
A. I don't believe I did.
6
Q. When did you learn that a search
7
warrant was executed for the Palm Beach
8
house?
9
A. I don't recall exactly.
10
Q. Were you present at the house in
11
advance of the search warrant being executed?
12
MR. PAGLIUCA: Object to the form
13
of the question.
14
A. I don't remember when the search
15
warrant was executed and I don't remember the
16
year that the search warrant was executed and
17
whenever that was, I already testified, I was
18
very, very infrequently at the house. So
19
highly unlikely but I was there a couple of
20
days, I just don't know which days it was in
21
relation to the police situation.
22
Q. Did you have a computer at the Palm
23
Beach home that was a computer that you would
24
use?
25
A. No.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 187 of 465
Page 187
1
G Maxwell - Confidential
2
Q. Was there a computer available for
3
use in the Palm Beach house?
4
A. Can you be more specific.
5
Q. Was there anywhere in the Palm
6
Beach house where there was a computer where
7
you said you worked for him and there were
8
other staff in the house, was there ever a
9
computer in the Palm Beach mansion that was
10
accessible by you or other staff?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I stopped being regularly at the
14
house sometime in 2003 so from 2003 to when
15
the police search was executed, I have no
16
memory of what there was or what there was
17
not. I can only testify for what was there
18
when I was present largely.
19
Q. So in 2003 when you were still
20
there, was there a computer that was
21
accessible to you or other staff at the
22
house?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. There was a desktop computer that



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 188 of 465
Page 188
1
G Maxwell - Confidential
2
people could use -- just like you would use
3
if you needed to go online to get something,
4
that people could use.
5
Q. Was that on a desk that you would
6
use in your work capacity when you were at
7
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 girls
11
whether they be under the age of 18 or over
12
the age of 18 on that computer?
13
A. I have no recollection of any naked
14
people on that computer when I was there in
15
2003, we are talking.
16
Q. What about from say '99 to 2003?
17
A. No, I can't recollect any naked
18
pictures.
19
Q. Why were the computers removed from
20
the house before the search warrant was
21
executed?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. I have no knowledge of anything
25
like that.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 189 of 465
Page 189
1
G Maxwell - Confidential
2
Q. Do you know where the computers are
3
now?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I don't know what computers you are
7
talking of and I have no idea what you are
8
referencing.
9
Q. In 2003 you said there was a
10
computer in a room on a desk?
11
A. Right.
12
Q. Do you know where that computer is
13
now?
14
A. I do not.
15
Q. Did you take pictures of nude
16
females in any of Epstein's homes or in and
17
around the homes, out by the pool or anywhere
18
like, in the Palm Beach home, the New York
19
home, USVI home or the New Mexico home?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. Can you repeat the question.
23
Q. Did you take pictures of nude woman
24
over 18 or under 18, females, in any of
25
Jeffrey Epstein's homes, inside or outside in



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 190 of 465
Page 190
1
G Maxwell - Confidential
2
or around the home?
3
A. I think we need to distinguish
4
between anyone under the age of 18 and over
5
the age of 18.
6
Q. We will start with, did you take
7
pictures of nude females in or around any of
8
Jeffrey's homes of women or females that were
9
under the age of 18?
10
A. No.
11
Q. Did you take pictures of nude
12
females --
13
A. Nude you mean with no clothing on.
14
Q. Or half nude, with no top on, any
15
sort of nakedness to an individual.
16
In any of Jeffrey's homes, either
17
Palm Beach, New Mexico, USVI or New York
18
either outside by the pool, anywhere in or
19
around those homes of females over the age of
20
18?
21
A. So it is possible that I took
22
pictures of people that were somehow semi or
23
had some clothing on or no clothes on but at
24
no time were any of these pictures remotely
25
inappropriate. They were, you could see them



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 191 of 465
Page 191
1
G Maxwell - Confidential
2
in a mainstream magazine today, there would
3
be no inappropriateness, they would be
4
covered, concealed, you wouldn't see anything
5
at all.
6
The types of -- first, I took very
7
few and they were always by request, this was
8
a picture you could put on your -- gift to
9
your parent or to your grandparents to put on
10
their mantel piece . It would be a very
11
benign sort of attractive picture where you
12
wouldn't see anything.
13
Q. Who would request those pictures?
14
A. From time to time, people, men and
15
women would ask to have nice photographs of
16
them taken.
17
Q. And did Jeffrey Epstein request
18
those pictures?
19
A. I don't ever recall him asking me
20
to take pictures.
21
Q. Did you give him pictures of naked
22
females as a present?
23
A. I don't recall ever giving a
24
present of -- I don't know why a photograph
25
would constitute a gift.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 192 of 465
Page 192
1
G Maxwell - Confidential
2
Q. Not as a gift.
3
Do you recall ever giving Jeffrey
4
Epstein pictures that you've taken of these
5
individuals in a naked state?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. First of all, we've already
9
established that they are not naked state
10
photographs.
11
Q. A piece of them being naked as you
12
described.
13
A. I said they would be attractive as
14
you would see in mainstream magazines and
15
those pictures could be a picture of a hand
16
or a foot, they didn't necessarily
17
constitute -- I know where you are headed
18
with this and it's nowhere appropriate and
19
it's really unattractive.
20
Q. I'm not headed anywhere. I'm just
21
asking the questions. Did you give Jeffrey
22
Epstein any of these pictures that you took
23
of females in the state that you described?
24
A. I can't recall ever giving him
25
pictures but it is possible that I took



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 193 of 465
Page 193
1
G Maxwell - Confidential
2
pictures of people that would end up -- or a
3
friend of his that he would have -- not naked
4
or not inappropriate in any way, that he
5
might have somewhere in his house.
6
Q. Name for me all the individuals who
7
you took these pictures of?
8
A. It's entirely impossible for me to
9
name people. First of all, it was just -- it
10
would not be possible, I took thousands of
11
photos, not of people, I mostly take pictures
12
of landscapes and things. I have no
13
recollection specifically of people that I
14
took pictures of.
15
Q. So you can't remember, is it your
16
testimony you can't remember one person that
17
you took a picture of in either a naked or
18
semi naked state?
19
A. I seriously cannot recall. I just
20
don't recall.
21
Q. Did you take a picture of Virginia
22
Roberts either alone or with another
23
individual in a naked state?
24
A. I have never taken, I believe, any
25
pictures of two people in any type of



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 194 of 465
Page 194
1
G Maxwell - Confidential
2
situation, naked as you describe.
3
Q. Did you take a picture of Virginia
4
Roberts on her own without another individual
5
in it in a naked state?
6
A. I don't recall ever taking a
7
picture of Virginia -- naked, we are not
8
referring to someone with no clothing on at
9
all, we are referring to someone that could
10
be semi clad or could have a towel or we are
11
not referring to anything inappropriate.
12
Q. Was this a hobby of yours to take
13
pictures of the type that you are describing?
14
MR. PAGLIUCA: Object to the form.
15
A. I just testified, I didn't take
16
pictures of many people. My preference is
17
pictures for landscapes and for architectural
18
pieces.
19
Q. Where are those pictures today?
20
A. I have no idea.
21
Q. Do you have them in your home?
22
A. I do not.
23
Q. Do you have them on your computer?
24
A. I do not.
25
Q. What has Jeffrey Epstein told you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 195 of 465
Page 195
1
G Maxwell - Confidential
2
about the allegations related to the criminal
3
investigation that he was involved in?
4
A. I really can't say, not because I
5
don't want to say but I just think of what he
6
has said to me over the course of this time.
7
Q. Did he explain it to you and
8
explain what the charges were against him?
9
A. I never had a detailed conversation
10
with him, as I recall.
11
Q. Not detailed, just did he explain
12
anything that was happening to him?
13
A. I haven't spoken to him for so
14
long. I can't possibly testify to what
15
conversations I had with him over the course
16
of time.
17
Q. Did he talk to you about any of the
18
girls that were making allegations against
19
him other than Virginia?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. You are talking about the police
23
records again, all of that?
24
Q. Yes.
25
A. I have never had a conversation



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 196 of 465
Page 196
1
G Maxwell - Confidential
2
about those things.
3
Q. What has Jeffrey Epstein told you
4
about Virginia Roberts?
5
A. That she is a liar.
6
Q. What does he base that on?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. You would have to check with him.
10
I can tell you why I think she is a liar, I'm
11
happy to do that.
12
Q. Did he tell you he did not have
13
sexual relations with Virginia Roberts?
14
A. I can only testify what I know.
15
Q. I'm asking, has he told you that he
16
did not have sexual relations with Virginia
17
Roberts?
18
A. I can only tell you what I know
19
about Virginia Roberts, I cannot tell you
20
what he knows about Virginia Roberts.
21
Q. I'm asking, did he tell you that he
22
did not have sexual relations with Virginia
23
Roberts?
24
A. All he told me is she is a liar.
25
Q. That's all he said about Virginia



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 197 of 465
Page 197
1
G Maxwell - Confidential
2
Roberts?
3
A. We went through all the lies that
4
you have sold to the papers and sold in
5
general and we have analyzed her lies and
6
your lies and your inappropriate behavior in
7
detail.
8
Q. Did he ever say that he did not
9
have sexual relations with Virginia Roberts?
10
A. I just testified that we went
11
through all of her lies.
12
Q. I understand what you said. I'm
13
asking you a question.
14
Did he ever tell you that he never
15
had sex with Virginia Roberts?
16
A. I don't recall whether he ever -- I
17
don't know I ever had that question. We
18
focused on the lies she did say she had with
19
him as relates to me. I don't remember
20
asking him about his problems with her. I'm
21
interested in what she says about myself.
22
Q. Did you also talk about what things
23
that Virginia Roberts was saying that were
24
true?
25
A. There isn't anything that she said



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 198 of 465
Page 198
1
G Maxwell - Confidential
2
that was true.
3
Q. Nothing she said that you are aware
4
of is true?
5
A. I think she is correct when she
6
talks about what her name is.
7
Q. Anything else?
8
A. I'm sure there must be one or two
9
other details but they are so far and few
10
between, I would have to look in detail at
11
all of her allegations to pinpoint what
12
possibly could be true.
13
Q. Did you ever ask Jeffrey if he had
14
sex with minors?
15
A. I have never been asked that
16
question.
17
Q. You never asked him that question.
18
What analysis did Jeffrey do to
19
determine that the statements Virginia
20
Roberts were making were lies?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. Ask me again, please.
24
Q. What analysis did Jeffrey do to
25
determine that the statements that Virginia



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 199 of 465
Page 199
1
G Maxwell - Confidential
2
Roberts were making were lies?
3
MR. PAGLIUCA: Objection to the
4
form and foundation. And to the extent
5
that any of this answer calls for any
6
privileged communication, I'm
7
instructing, with myself or another
8
lawyer representing you or in any common
9
interest agreement, I'm instructing you
10
not to answer.
11
MS. McCAWLEY: The court ruled she
12
is entitled and you had to produce
13
documents about communications with
14
Jeffrey, that's what I'm asking about.
15
I'm not asking about communications with
16
lawyers.
17
Q. I'm asking what analysis did
18
Jeffrey do to determine that the statements
19
that Virginia Roberts was making were lies,
20
if you know?
21
MR. PAGLIUCA: My objection is to
22
the extent she learned any of that
23
information as a result of either a
24
privileged communication from a lawyer,
25
one of her lawyers or a privileged



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 200 of 465
Page 200
1
G Maxwell - Confidential
2
communications subject to a joint
3
defense agreement or common interest
4
agreement, I'm telling her not to
5
answer. To the extent she has
6
information outside of those things, she
7
is permitted to answer.
8
Q. Do you understand?
9
So if it was a conversation with a
10
lawyer which I'm not asking about, I don't
11
want you to tell me about your conversations
12
with lawyers.
13
I want you to tell me whether
14
Jeffrey Epstein ever told you what he
15
analyzed in order to determine which of -- of
16
what Virginia were saying were lies?
17
A. I do not know what he did, no.
18
So you agree she is lying, Singrid.
19
Q. I do not agree with that and I'm
20
asking the questions.
21
A. You just said her lies.
22
Q. I'm repeating a statement you made.
23
Q. Are you saying it's an obvious lie
24
that Jeffrey Epstein engaged in sexual
25
conduct with Virginia while Virginia was



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 201 of 465
Page 201
1
G Maxwell - Confidential
2
underage?
3
A. I can only testify to what I saw
4
and what I was present for, so if you are
5
asking me what I saw then I am happy to
6
testify. I cannot testify to what somebody
7
else did or didn't do.
8
Q. Did you issue a statement
in 2015, stating that
10
Virginia Roberts' claims were, quote, obvious
11
lies?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
Q. You can answer.
15
A. You need to reask me the question.
16
Q. Sure.
17
Did you issue a press statement
18
in
19
January of 2015, stating that Virginia
20
Roberts' claims were, quote, obvious lies?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. Can you ask it a different way,
24
please?
25
Q. I will ask it again and you can




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 202 of 465
Page 202
1
G Maxwell - Confidential
2
listen carefully.
3
Did you issue a press statement
4
in
5
January of 2015, where you stated that
6
Virginia Roberts' claims were, quote, obvious
7
lies?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. So my lawyer,
11
instructed
to issue a statement.
12
Q. Today, did you say that Virginia
13
lied about, quote, absolutely everything?
14
A. I said that there are some things
15
she may not have lied about.
16
Q. So are you saying it's an obvious
17
lie that Jeffrey Epstein engaged in sexual
18
contact with Virginia while Virginia was
19
underage?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. Can you ask the question again,
23
please?
24
Q. Are you saying it's an obvious lie
25
that Jeffrey Epstein engaged in sexual



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 203 of 465
Page 203
1
G Maxwell - Confidential
2
conduct with Virginia while Virginia was
3
underage?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
Q. You can answer.
7
A. Try again, please.
8
Q. Are you saying that it's an obvious
9
lie that Jeffrey Epstein engaged in sexual
10
conduct with Virginia while Virginia was
11
underage?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. Again, I'm telling you, first of
15
all, it was a statement that was issued by my
16
lawyer and -- through my lawyer
.
17
Q. I understand that. I'm asking you,
18
are you saying that it's an obvious lie that
19
Jeffrey Epstein engaged in sexual conduct
20
with Virginia while Virginia was underage.
21
Is that a lie?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
Q. You can answer.
25
A. So I cannot testify to what



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 204 of 465
Page 204
1
G Maxwell - Confidential
2
and
decided to put -- I can
3
testify to what Virginia's obvious lies are
4
as regards to me. I cannot make
5
representations about all the many lies she
6
may or may not have told about Jeffrey.
7
Q. So is Virginia lying when she says,
8
is it an obvious lie when she says that she
9
had sex with Jeffrey Epstein while she was
10
underage?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. Again, I'm testifying to what I
14
know to be true. I can only testify to all
15
the many lies she told about me. I cannot
16
testify to what lies she told about somebody
17
else. Given she told so many about me, one
18
can probably infer she is lying about
19
everything.
20
Q. So you think she is lying when she
21
said she had sex with Jeffrey Epstein when
22
she was underage?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Again, I can only talk about what I



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 205 of 465
Page 205
1
G Maxwell - Confidential
2
can positively say myself, not what somebody
3
else is going to represent.
4
Q. When you were saying that she was,
5
her claims of having sex with Jeffrey Epstein
6
were obvious lies, are you saying she is
7
lying about engaging in sexual conduct with
8
Jeffrey Epstein when she was underage?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
Q. You can answer.
12
A. Again, this was a statement that
13
was put out from my lawyer
And I can only testify to
15
the obvious lies that she says about me. I
16
cannot make representations about lies she
17
says about someone else, but she lies so many
18
times about me, one can probably infer she is
19
lying about everything.
20
Q. So is she not lying when -- is she
21
telling the truth when she says she had sex
22
with Jeffrey Epstein when she was underage?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Again, I don't know how else to




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 206 of 465
Page 206
1
G Maxwell - Confidential
2
tell you, I can only talk about what I know
3
to be true. What I know is her story about
4
how she claims that initial situation
5
happened is so egregiously false and such a
6
giant fat enormous, repulsive, disgusting,
7
inappropriate, vile lie, that that I can
8
testify to.
9
Q. Was she lying when she said she met
10
you at Mar-a-Lago?
11
A. Again I already testified I don't
12
recall meeting her at Mar-a-Lago.
13
Q. We showed you a document where you
14
said you met her at Mar-a-Lago when she was
15
17, is that correct?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. I think I already testified to
19
that. What I remembered based on all the
20
rubbish she has written and all the many
21
articles I have read, maybe in the moment
22
when I wrote that, have caused me to have
23
that but on reflection I don't recall it as I
24
sit here today.
25
Q. Are you saying that it was an



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 207 of 465
Page 207
1
G Maxwell - Confidential
2
obvious lie that you approached Virginia
3
while she was under age at Mar-a-Lago?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. First of all, we can all agree
7
here, all of you sitting here that the lies
8
that you perpetrated in the press that she
9
was 15 and we should all agree now that that
10
is fake, a lie that was perpetrated between
11
all of you to make the story more exciting,
12
can we agree on that?
13
Q. That is not my question.
14
A. Can we agree she was not the age
15
she said and you put that in the press, that
16
is obviously, manifestly, absolutely, totally
17
a lie.
18
MS. McCAWLEY: I am going to put on
19
the record, Ms. Maxwell very
20
inappropriately and very harshly pounded
21
our law firm table in an inappropriate
22
manner. I ask she take a deep breath,
23
and calm down. I know this is a
24
difficult position but physical assault
25
or threats is not appropriate, so no



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 208 of 465
Page 208
1
G Maxwell - Confidential
2
pounding, no stomping, no, that's not
3
appropriate,.
4
A. Can we be clear, I didn't threaten
5
anybody.
6
MR. PAGLIUCA: Stop, you made your
7
record, there is no dent in the table.
8
I don't see any chips. Can we take a
9
break now.
10
MS. McCAWLEY: I think it's
11
appropriate to take a break.
12
THE VIDEOGRAPHER: It's 1:56 and we
13
are off the record.
14
(Recess.)
15
THE VIDEOGRAPHER: It's now 2:13,
16
we're starting disk No. 5 and we are
17
back on the record.
18
Q. Ms. Maxwell, how old was Virginia
19
Roberts when you met her in Mar-a-Lago?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I know today that she was 17 years
23
old.
24
Q. Are you saying that it's an obvious
25
lie that Virginia traveled on Jeffrey



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 209 of 465
Page 209
1
G Maxwell - Confidential
2
Epstein's airplanes?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
Q. You can answer.
6
A. Are you referring to my statement
7
where that says that?
8
Q. I'm referring to the language you
9
use in your statement that says, obvious
10
lies?
11
A. Can you read my entire statement?
12
Q. Sure, let me pass it out.
13
(Maxwell Exhibit 10, email,marked
14
for identification.)
15
Q. This is Bates GM 00068 and we will
16
mark it as -- what you have in front of you
17
is a statement at the top. This was produced
18
by your counsel, it is indicated Bates No.
19
GM 00068. At the top the date reflects
20
January 2, 2015 from, appears to be a
21
, subject line, is you and
22
then there is a number of individuals you can
23
see at the top that are copied on this that
24
is sent to and bcc'd on this statement.
25
The statement, there are two parts



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 210 of 465
Page 210
1
G Maxwell - Confidential
2
of it. There is an opening email that says,
3
please find an attached quotable statement on
4
behalf of Ms. Maxwell and there is more
5
language there and it's from
and
6
then it says in the body of it, Jane Doe No.
7
3 or Jane Doe 3 is Virginia Roberts so not a
8
new individual. The allegations made by, and
9
it says Victoria but I believe that means
10
Virginia Roberts, against Ghislaine Maxwell
11
are not true. The original allegations are
12
not new and have been fully responded to and
13
shown to be untrue. And the next paragraph
14
says, Each time the story is retold, it
15
changes with new salacious details about
16
public figures and world leaders and now it
17
is alleged by Ms. Roberts that
18
is involved in having sexual relations with
19
her which he denies. Ms. Roberts claims are
20
obvious lies and should be treated as such
21
and not publicized as news as they are
22
defamatory.
23
The last paragraph states,
24
Ghislaine Maxwell's original response to the
25
lies and defamatory claims remains the same.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 211 of 465
Page 211
1
G Maxwell - Confidential
2
Maxwell strongly denies allegations of the --
3
strongly denies allegations of an unsavory
4
nature which have appeared in the British
5
press and elsewhere and reserves her right to
6
seek redress at the repetition of such old
7
defamatory claims.
8
Are you saying that it's an obvious
9
lie that Virginia Roberts traveled on Jeffrey
10
Epstein's planes?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I'm saying what's an obvious lie
14
and I think we can all agree, you just had
15
the case tossed out by
. He
16
just got removed from the case because you
17
put him in a case that he wasn't supposed to
18
be in so what was said about him is not true.
19
Q. Are you saying that it's an obvious
20
lie that Virginia Roberts traveled on Jeffrey
21
Epstein's plane?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. You have given me plane records
25
that has her name on it but as I already



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 212 of 465
Page 212
1
G Maxwell - Confidential
2
testified those aren't federally mandated
3
things and I can see her name on it but
4
that's what I -- I told you I don't recall
5
her on any planes.
6
Q. Is is that one of Virginia's
7
obvious lies?
8
A. There are more obvious ones.
9
Q. Is that one of them?
10
A. I can't testify to her being on a
11
plane or not.
12
Q. So is that an obvious lie?
13
A. There are more obvious lies, like
14
15
Q. I understand there are more obvious
16
ones. I'm asking you, is the fact that she
17
said she traveled on Epstein's planes an
18
obvious lie?
19
A. I think we can probably say because
20
you see her name on a plane record and she
21
went from A to B, that would not be the
22
obvious lie that I would pick.
23
Q. What obvious lie were you picking
24
when you made this statement?
25
A. There are so many that I would be



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 213 of 465
Page 213
1
G Maxwell - Confidential
2
thrilled to go through all of them.
3
Q. Let's go through them.
4
What's the first one?
5
A. Her characterization of the first
6
meeting at Mar-a-Lago.
7
Q. What part of that was an obvious
8
lie?
9
A. The characterization that she said
10
that she said she was accosted. She looked
11
like, as best as I can recall, if I met her
12
in Mar-a-Lago as she claims, she worked at
13
Mar-a-Lago, she claims, and her statement she
14
worked at Mar-a-Lago, she would have been
15
dressed as all the spa people in Mar-a-Lago
16
would have been. It would have been
17
impossible to identify her as someone other
18
than someone who worked at a spa. She made
19
many claims, she has been a bathroom
20
attendant, front of house attendant, we don't
21
know what she was, so her obvious lies are
22
her contradictory of her own personal
23
statements within that.
24
Q. So what part of her statement
25
relating to Mar-a-Lago --



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 214 of 465
Page 214
1
G Maxwell - Confidential
2
A. I'm carrying on.
3
Q. I'm sorry. I thought you were
4
done.
5
A. Please. Her statement also that
6
she was driven by her father to Palm Beach.
7
She was driven by her mother, as a matter of
8
fact. Her whole entire characterization of
9
the first meeting with Jeffrey, as I was
10
outside speaking to her mother.
11
Q. Let me stop you there, so we don't
12
get too far ahead. Let me make sure I
13
understand your testimony.
14
The first, in the first piece when
15
you were talking, I believe you said and
16
correct me if I'm wrong, that her
17
characterization of the first meeting at
18
Mar-a-Lago was an obvious lie.
19
What part of that meeting was an
20
obvious lie?
21
A. By her own testimony, all her
22
various many different descriptions of what
23
she was or wasn't or where she was or wasn't,
24
they have all changed. She was either front
25
of house or bathroom attendant. I don't know



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 215 of 465
Page 215
1
G Maxwell - Confidential
2
what she was, so just by her own words, one
3
doesn't know what's true and what isn't true.
4
Q. Are you saying what position she
5
said she was working in, is that what you are
6
considering the obvious lie?
7
A. I said inconsistency within her own
8
statement from everything, so in the
9
beginning it starts off with different
10
statements.
11
Q. Then I believe you said the second
12
piece was that she was driven by her father?
13
A. I said she was driven by her
14
mother.
15
Q. That's the obvious lie?
16
A. It's an obvious lie to me.
17
Q. You said why don't you state it in
18
your own words but the characterization of
19
how she was with Jeffrey, what about that is
20
an obvious lie?
21
A. I was standing outside talking to
22
her mother so the entire story is a
23
fabrication.
24
Q. Did she not have sex with Jeffrey
25
Epstein during that first massage?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 216 of 465
Page 216
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I was talking to her mother so...
5
Q. Do you know whether that's an
6
obvious lie, whether she had sex in that room
7
or not?
8
A. Her story about what happened --
9
let's also be -- the story as first hit the
10
press was that somebody else led her to
11
Jeffrey's room, it was not me and then it
12
turned to being me so we have an obviously
13
important inconsistency, lie in my -- that's
14
how I would characterize a lie. It cannot be
15
me or somebody else, it can only be one or
16
the other.
17
Q. Who is the other person she said
18
took her to the room?
19
A. Why don't you ask her.
20
Q. I'm asking you.
21
A. How would I possibly know.
22
Q. You are saying that's a lie.
23
A. It was a lie in the papers, she
24
said it in the newspaper, it was in the
25
newspaper.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 217 of 465
Page 217
1
G Maxwell - Confidential
2
Q. How do you know she wasn't
3
identifying you?
4
A. She said somebody.
5
Q. How do you know that somebody
6
wasn't you?
7
A. Why did it suddenly become me, why
8
not say it was me and be done with it.
9
Q. So it's a lie because she
10
originally may not have named you and then
11
named you later?
12
A. It's obviously inconsistent to
13
somebody who wasn't me.
14
Q. How do you know it wasn't you?
15
A. I know it wasn't me because I was
16
talking to her mother.
17
Q. But she then named you, is what you
18
are saying?
19
A. That's an obvious lie.
20
Q. She named you?
21
A. It's an obvious lie because I
22
wasn't even in the house.
23
Q. Is it an obvious -- who did lead
24
her up to Jeffrey's room while you were
25
talking to her mother?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 218 of 465
Page 218
1
G Maxwell - Confidential
2
A. You would have to ask Virginia, I
3
don't know if she was led up to his room.
4
Q. You were standing with the mother,
5
is that correct?
6
A. That's correct.
7
Q. Who was working at the house that
8
day?
9
A.
.
10
A. Would
typically lead
11
someone up to the room where Jeffrey was
12
having a massage?
13
A. I don't know she was led up to the
14
room to have a massage.
15
Q. She would have found her way on her
16
own?
17
A. I would suggest that that entire
18
story never happened at all in any of its
19
form.
20
Q. If you stood outside with the
21
mother, what did you think happened inside
22
then?
23
A. I believe that somebody, it wasn't
24
me,
probably took her to meet
25
Jeffrey Epstein



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 219 of 465
Page 219
1
G Maxwell - Confidential
2
.
3
Q. Did Jeffrey tell you that?
4
A. No but that would have been a
5
normal interaction. I don't believe for a
6
second -- I know her entire characterization
7
didn't happen because I was outside talking
8
to her mother the entire time.
9
Q. Why would she have come for a
10
massage and not given a massage?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. We are talking about her
14
characterization of the first time that she
15
came to the house.
16
Q. If I'm following you correctly,
17
you're saying she walked in and would have
18
gone to -- it's your assumption she would
19
have gone and talked to Jeffrey and left?
20
A. When I was working for Jeffrey,
21
typically he would meet someone before
22
getting a massage from them to see if he
23
wanted to have a massage from them,
24
typically.
25
Q. So he would not have someone come



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 220 of 465
Page 220
1
G Maxwell - Confidential
2
up to the room and start a massage?
3
A. He would not.
4
Q. So the young girls in the police
5
report who say they came over and were led up
6
to the room on the first day, would they be
7
wrong about that?
8
MR. PAGLIUCA: Objection to form
9
and foundation.
10
A. I can't comment what happened when
11
I was not at the house. I can only comment
12
when I was at the house.
13
Q. Was there ever a time where a woman
14
came to the house for the first time to give
15
a massage and Jeffrey had the massage that
16
day?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. Can we talk about adult
20
professional masseuses, please?
21
Q. I'm asking, whether adult or
22
underage?
23
A. I'm not interested in talking about
24
underage. I can only testify to what I know,
25
professional masseuses, adult, I cannot



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 221 of 465
Page 221
1
G Maxwell - Confidential
2
testify to anything else.
3
Q. Why can't you testify to an
4
underage girl that came over and was led up
5
to the room for a massage?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. The police records you are
9
referring to?
10
Q. You are saying that didn't happen.
11
You're saying I can only testify to adults
12
that came for an interview and were led up to
13
the room. Why can't you testify to whether
14
an underage girl was brought in for an
15
interview and led up --
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
Q. Go ahead.
19
A. Can you reask the question.
20
Q. Why can't you testify as to an
21
underage girl who came over for an interview
22
and then was then led up to the room for the
23
massage?
24
A. You've mangled your entire
25
question. Can you please reask that in a way



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 222 of 465
Page 222
1
G Maxwell - Confidential
2
that I can answer it correctly?
3
Q. Why can you not testify as to
4
whether an underage girl, you said you can
5
testify as to females that were over the age
6
of 18, why can't you testify as to whether an
7
underage girl came over for an interview and
8
on the same day --
9
A. I don't know what you mean by
10
interview.
11
Q. You just said that Jeffrey Epstein
12
interviewed, it was your word, interviewed
13
the masseuses before they gave massages, is
14
that correct?
15
A. The word interview is making me --
16
I'm English, so you could have some
17
difficulty understanding the way I
18
communicate.
19
Q. I'm using your word.
20
A. Then I will reuse it a different
21
word. He would meet them because receiving a
22
massage is something you want to make sure
23
you are comfortable with the person and so
24
interview is not the correct word but you
25
would meet them to have a conversation with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 223 of 465
Page 223
1
G Maxwell - Confidential
2
them to see if you want to have a massage
3
with that person.
4
Q. Did Jeffrey Epstein ever meet an
5
underaged girl and on the same day receive a
6
massage from that girl?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I can't possibly testify to what
10
happened after I was not at the house.
11
Q. If you are aware, at any time you
12
were at the house, did you ever see that?
13
MS. MENNINGER: Let her finish the
14
question.
15
A. I can only testify to people who
16
were adult professional masseuses who came to
17
the house. I cannot testify to something I'm
18
not party to and don't know about. I can
19
only testify to what I saw. So when
20
professional adult masseuse, male and/or
21
females would come to the house, typically
22
when I was there, typically he would meet
23
with them prior, to have a conversation with
24
them about their experience, whatever, to
25
decide whether it would then A, if he had



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 224 of 465
Page 224
1
G Maxwell - Confidential
2
time for a massage at that time or B, whether
3
he could have a massage at that moment.
4
Q. Was Virginia an adult when she came
5
over, was she over 18?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I think we established, as of
9
today, we are all aware, everyone in this
10
room that she was 17.
11
Q. So you have been present when a
12
minor was brought over for a massage for
13
Jeffrey?
14
A. Can I say, as you are able to have
15
a massage at 17, so she came as a masseuse.
16
Q. I'm not saying whether or not you
17
are able to. I'm saying you've been present
18
at Jeffrey's home when an underage minor has
19
come over to give him a massage?
20
A. That's just not how that works.
21
You are able to be a masseuse at 17 so she
22
came to give -- for a massage, at 17 you are
23
able to come and give a massage.
24
Q. I'm not asking whether she is able
25
to do it. I'm asking whether you were



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 225 of 465
Page 225
1
G Maxwell - Confidential
2
present at the home when a girl under the age
3
of 18 came over for the purposes of giving a
4
massage?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
Q. You can answer.
8
A. You can be a professional masseuse
9
at 17 in Florida, so as far as I am aware, a
10
professional masseuse showed up for a
11
massage. There is nothing inappropriate or
12
incorrect about that and your
13
mischaracterization of it, I think is
14
unfortunate.
15
Q. How many teenagers did he have that
16
were professional masseuses that worked in
17
his home?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
Q. How many?
21
A. First of all, I am not aware of
22
teenagers who worked in his home.
23
Q. You are aware of Virginia Roberts
24
and you've stated she was 17 and she worked
25
for him, correct?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 226 of 465
Page 226
1
G Maxwell - Confidential
2
A. No. I did not state that at all,
3
you are mischaracterizing my words and what I
4
said.
5
What I said was that we can all
6
agree and I think at this point there is not
7
one person in this room, however much you
8
would like her to be younger, to say she was
9
not 17 because that has been a very offensive
10
thing that you have all done. So she was 17.
11
At 17 you are allowed to be a professional
12
masseuse and as far as I'm concerned, she was
13
a professional masseuse. There is nothing
14
inappropriate or incorrect about her coming
15
at that time to give a massage. Her entire
16
characterization of her first time at the
17
house was to me an obvious lie, given it was
18
impossible for her entire story to take place
19
given I was speaking to her mother the entire
20
she was at the house.
21
Q. So it was impossible that day, that
22
first day she came and you were speaking to
23
the mother, for Virginia Roberts to have had
24
sex with Jeffrey Epstein during the time that
25
you were outside with her mother?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 227 of 465
Page 227
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. You, again, are completely
5
mischaracterizing. I can only testify to
6
what I heard obvious lies about me and her
7
obvious lies about me are that she, as you
8
put out to the papers and every other which
9
way, went upstairs with her, didn't happen.
10
So that to me is an absolute, obvious lie. I
11
also don't believe that her -- her
12
mischaracterization of the length of time she
13
was there because as I recall, she just met
14
with Jeffrey and then left with her mother.
15
That's my recollection.
16
Q. So you were standing outside the
17
entire time that Virginia was in the house,
18
is that correct?
19
A. That is correct.
20
Q. So can you testify as to whether or
21
not, do you know either from Jeffrey or any
22
other source whether or not Virginia Roberts
23
had sex with Jeffrey on that first day that
24
she was at the house?
25
A. We can categorically state,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 228 of 465
Page 228
1
G Maxwell - Confidential
2
absolutely 1000 percent that she did not have
3
any type of sexual relations as described by
4
you in your court papers that took place
5
because those allegedly according to her lies
6
involved some aspect of me.
7
As I was standing outside with her
8
mother the entire time, her entire story is a
9
lie. Therefore, to ask me what she did or
10
didn't do during that time, I can only
11
testify to what she said about me, which was
12
1000 percent false.
13
Q. So let's not take the first time,
14
let's take the next time she comes.
15
A. No no, how can do you that, when
16
the basis of this entire horrible story that
17
you have put out is based on this first
18
appalling story that was written, repeated,
19
multiply by the press that lied about her
20
age, lied about the first time she came, lied
21
about and characterized the entire first
22
time. I have been so absolutely appalled by
23
her story and appalled by the entire
24
characterization of it and I apologize
25
sincerely for my banging at the table



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 229 of 465
Page 229
1
G Maxwell - Confidential
2
earlier, I hope you accept my apology. It's
3
borne out of years of feeling the pressure of
4
this entire lie that she has perpetrated from
5
our first time and whilst I recognize that
6
was -- I hope you forgive me sincerely
7
because it was just the length of time that
8
that terrible story has been told and retold
9
and rehashed when I know it to be 100 percent
10
false.
11
Q. So not the first time she came, but
12
the second time she came or the third time or
13
any time she came, did you ever participate
14
in a massage with her in Jeffrey Epstein's
15
room?
16
A. I have never participated at any
17
time with Virginia in a massage with Jeffrey.
18
Q. Have you ever participated at any
19
time with Virginia in any kind of sexual
20
contact or sexual touching with Jeffrey and
21
Virginia?
22
A. I have not.
23
Q. So we were going through the list
24
of obvious lies and you were talking about
25
the first time which I believe we have



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 230 of 465
Page 230
1
G Maxwell - Confidential
2
completed but you can add to that if you need
3
to.
4
What other obvious lies did
5
Virginia Roberts tell that you were referring
6
to in your statement?
7
A. Oh my goodness. Well, I think we
8
can totally cover the
story, the
9
story that I flew him with
and
10
there was a dinner with other people and that
11
entire thing is 100 percent fictitious. I
12
have testified for the record and I'm happy
13
to do it again, that I have never flown
14
myself as a pilot in a helicopter at
15
any time, anyplace, at any time, to any part
16
of the world.
17
Q. What other obvious lies were you
18
referring to?
19
A. She was referring to
, she
20
is referring to a bunch of people. I don't
21
believe
ever came to the island at
22
any time ever. I don't even know
23
actually.
24
Q. Just one moment, I want to hear all
25
of them, but when you say you don't believe



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 231 of 465
Page 231
1
G Maxwell - Confidential
2
ever came to the island, do you know
3
whether
ever came to the island?
4
A.
never came to the island.
5
Q. How do you know that?
6
A. Jeffrey doesn't know him, I don't
7
know him and I think had
-- I don't
8
think -- had
gone to the island
9
during the period when I would have been
10
involved in organizing a trip, I would have
11
been aware of it.
12
Q. So go ahead, you had another one.
13
A. It would be easier if I could see,
14
do you mind if a take a reference at some of
15
these newspaper articles or you just want me
16
to go from memory.
17
Her entire characterization of what
18
took place in London at my house with
19
20
Q. Was it an obvious lie that she was
21
at your house in London?
22
A. We can't really establish the
23
photograph and all that. I don't know if
24
that's true, if that's a real picture or not.
25
Q. So you dispute that you were



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 232 of 465
Page 232
1
G Maxwell - Confidential
2
actually photographed in your town home in
3
London --
4
A. I don't recognize that picture.
5
I'm not sure if that's a real picture or not.
6
Q. And have you talked to
7
about that picture?
8
A. We discussed Virginia's entire tail
9
and he asked me if he even knew her.
10
Q. So did
tell you that
11
he did not have sex with Virginia Roberts?
12
A. He doesn't even know who Virginia
13
Roberts is.
14
Q. Did he tell you that he didn't have
15
sex with her?
16
A. It would be difficult to have sex
17
with someone you don't know.
18
Q. He may not remember her?
19
A. I think the inference is he didn't
20
know who she was, he didn't have any
21
recollection of her whatsoever.
22
Q. Has
ever come to your
23
London town home?
24
A. Yes. Ever being the entire time I
25
owned my house, yes.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 233 of 465
Page 233
1
G Maxwell - Confidential
2
Can I go on on her obvious lies?
3
Q. If you have more.
4
A. I have -- her entire
5
characterization -- I took her shopping into
6
Burberry and bought her a very expensive
7
dress and if this photo were real and if this
8
is -- I would never -- the outfit doesn't
9
work at all so --
10
Q. Do you not remember taking her
11
shopping or are you saying it's an obvious
12
lie, you know you did not take her shopping?
13
A. I did not take her shopping. I did
14
not by her a $5,000 handbag.
15
Q. Did Jeffrey by her a $5,000
16
handbag?
17
A. Her accusation was that I did.
18
Q. Do you know if Jeffrey bought her a
19
handbag during that trip to London?
20
A. I don't know what he did. She
21
accused me, I can't physically remember
22
buying a $5,000 not for her, not for anyone,
23
not for me.
24
Q. Did you ever go shopping with
25
Virginia?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 234 of 465
Page 234
1
G Maxwell - Confidential
2
A. I don't recall ever shopping with
3
Virginia.
4
Q. Did you have more to go over or did
5
you want me to ask my questions?
6
A. The entire characterization of what
7
took place in my house in London would have
8
been impossible.
9
Q. Can I ask, do you still have it,
10
the picture of the London town home with you
11
in it, Giuffre 00407.
12
As you are looking at this picture,
13
Ms. Maxwell, as I'm looking at it it's on the
14
right-hand side, there appears to be a
15
picture hanging on the wall, do you recall
16
that in your London town home?
17
A. It's a little difficult to see.
18
Q. Do you recall having a picture on
19
the wall there by the room where you're
20
standing?
21
A. I do have a picture.
22
Q. Do you recall on the left-hand side
23
having a railing that looks like that with
24
sort of a bubble wood top?
25
A. I do.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 235 of 465
Page 235
1
G Maxwell - Confidential
2
Q. So are you saying that it's an
3
obvious lie that Virginia's statement that
4
she had sex with
is an obvious
5
lie?
6
A. What I'm representing is that her
7
entire ludicrous and absurd story of what
8
took place in my house is an obvious lie.
9
Q. Including she had sex with
10
11
A. She claimed things took place in my
12
bathroom in London. Her characterizations is
13
just not possible.
14
Q. So you're saying it's an obvious
15
lie -- that she was telling an obvious lie
16
when she said she had sex with
?
17
MR. PAGLIUCA: Objection to the
18
form and foundation. The witness
19
answered the question.
20
A. I'm saying within the context of
21
all the stories she told, this particular
22
story -- back up, she claimed we went out at
23
night.





Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 236 of 465
Page 236
1
G Maxwell - Confidential
2
. She characterized
3
that
.
4
.
5
She then characterized things took
6
place in my bathroom in the bathtub itself.
7
The tub is too small for any type of activity
8
whatsoever.
9
Q.
11
A.
13
Q. That would be
14
15
A. Yes.
16
Q. Are you saying that it was an
17
obvious lie when Virginia said that you made
18
her dress up in a school girl outfit?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I already testified that, first of
22
all, I don't know what you are taking about,
23
I already testified I didn't get her outfits
24
and all of that.
25
Q. Is it an obvious lie that Virginia





Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 237 of 465
Page 237
1
G Maxwell - Confidential
2
was paid to go to give a massage to
3
?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I cannot testify to what Virginia
7
did outside of -- I can't testify to what she
8
did, who she gave massages to.
9
Q. So you don't know on that one?
10
A. Of course I don't know.
11
Q. Do you agree that it's
12
psychologically harmful to have sex with a
13
minor?
14
MR. PAGLIUCA: Objection to form
15
and foundation.
16
A. What are you asking me?
17
Q. I'm asking if is it psychologically
18
harmful for an adult to have sex with a
19
minor?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I don't know what you are asking.
23
This has nothing to do with Virginia Roberts.
24
Q. It does.
25
A. How does it?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 238 of 465
Page 238
1
G Maxwell - Confidential
2
Q. I ask the questions, you answer.
3
If you can't answer, you can say I don't
4
know.
5
But my question is, do you agree
6
that it's psychologically harmful to have sex
7
with a minor?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. Are you giving me a random question
11
and as not relates to this case and not
12
relates to anything. It's obviously not
13
something that you want to have happen.
14
Q. Do you agree that Jeffrey Epstein
15
has harmed many minors by having sex with
16
them?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I can't testify to what Jeffrey did
20
or didn't do. I have no knowledge of what
21
you are asking me.
22
Q. If Jeffrey had sex with minors,
23
would you agree that that could harm a minor?
24
MR. PAGLIUCA: Object to the form
25
and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 239 of 465
Page 239
1
G Maxwell - Confidential
2
A. Again, I am not testifying to what
3
Jeffrey did or did not do because I cannot.
4
Q. You don't know whether Jeffrey
5
Epstein ever had sex with a minor?
6
A. Again, I cannot testify to what
7
Jeffrey did or didn't do. I cannot.
8
Q. You never observed him having sex
9
with a minor?
10
A. I never observed Jeffrey having sex
11
with a minor.
12
Q. Do you agree that calling a sex
13
abuse victim a liar when she speaks about her
14
abuse can cause psychological harm?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. Can you repeat the question.
18
Q. Do you agree calling a sex abuse
19
victim when she speaks about her abuse can
20
cause psychological harm?
21
MR. PAGLIUCA: Objection to form
22
and foundation.
23
A. Say it again.
24
Q. Do you agree that calling a sexual
25
abuse victim a liar can cause psychological



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 240 of 465
Page 240
1
G Maxwell - Confidential
2
harm.
3
MR. PAGLIUCA: Object to the form
4
form and foundation.
5
A. I would like to say all the
6
terrible things Virginia Roberts said about
7
me is extremely harmful and you should turn
8
that around. All the lies she has said and
9
you have backed her on have been extremely
10
damaging to me.
11
So what I can testify to is that
12
somebody who has made these outrageous
13
allegations and who is a serious liar and
14
that I know for a fact is a liar, that I can
15
testify is damaging to me.
16
Q. Do you agree that calling a sexual
17
abuse victim a liar when she speaks out about
18
her abuse can cause psychological harm?
19
MR. PAGLIUCA: Are you asking a
20
hypothetical question?
21
MS. McCAWLEY: Yes.
22
A. You are asking me to speculate?
23
Q. I'm not asking you to speculate .
24
If somebody is a sexual abuse victim --
25
A. I can't testify to what some random



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 241 of 465
Page 241
1
G Maxwell - Confidential
2
hypothetical person that you are asking me to
3
speculate on their mental state or health
4
versus speculative statement. I can't do
5
that, that's just not right.
6
Q. Do you agree that by calling
7
Virginia Roberts a liar when she was subject
8
to sexual abuse by Jeffrey Epstein can cause
9
psychological harm?
10
MR. PAGLIUCA: Objection to the
11
form and foundation. Assumes facts not
12
in evidence.
13
A. I can only tell you about what I
14
know of Virginia's lies. She lied
15
repeatedly, often and I know for a fact she
16
is a liar so I can only testify to what I
17
know and the fact that she has lied about me
18
from the beginning to the end and repeatedly
19
causes me to question anything that she may
20
feel.
21
Q. Is it an obvious lie you had sex
22
toys in Jeffrey Epstein's Palm Beach house?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Can you repeat the question,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 242 of 465
Page 242
1
G Maxwell - Confidential
2
please?
3
Q. Is it an obvious lie that you had
4
sex toys in Jeffrey Epstein's Palm Beach
5
house?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. Did Virginia say that?
9
Q. I'm asking you a question.
10
Is it an obvious lie that you had
11
sex toys in Jeffrey Epstein's house?
12
A. I don't recall any sex toys.
13
Q. If someone said had you sex toys,
14
would that be an obvious lie?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. Like I said -- can you be more
18
specific about the house or whatever, what
19
exactly you are referring to, what's a sex
20
toy?
21
Q. Yes. How would you define a sex
22
toy?
23
A. No. I need you to define a sex
24
toy, I don't have enough knowledge of sex
25
toys.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 243 of 465
Page 243
1
G Maxwell - Confidential
2
Q. I will define it based on the
3
dictionary's definition, which is an object
4
or device used to sexually stimulate or
5
enhance sexual pleasure.
6
A. What's your question, please?
7
Q. The question is, is it an obvious
8
lie that you had sex toys in Jeffrey
9
Epstein's Palm Beach house?
10
MR. PAGLIUCA: Same objection.
11
Q. You can answer.
12
A. Like I said, I do not have any
13
recollection of sex toys in Jeffrey's house.
14
Q. Is it a lie, is it an obvious lie
15
that you took pictures of nude girls?
16
MR. PAGLIUCA: Object to the form
17
and foundation.
18
A. We already covered this. Girls we
19
are not referring to -- I can only testify to
20
taking pictures of adult people and I already
21
testified they are not nude, per se. That
22
every picture that I ever took and which they
23
were very limited, always by request, the
24
people would be covered or it would be a hand
25
or a foot. There was never any pictures that



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 244 of 465
Page 244
1
G Maxwell - Confidential
2
I took of people would only have been
3
mainstream type magazine type photos and any
4
photos I took could have been very happily
5
and expected to be displayed on your parents'
6
mantel piece or grandparents' mantel piece.
7
Q. Is it a lie that you approached
8
females to bring them to Jeffrey Epstein?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. Please ask the question, again.
12
Q. Sure. Is it a lie that you
13
approached females to bring them to Jeffrey
14
Epstein?
15
A. I don't know what you are asking
16
me.
17
Q. I'm asking you, if it's a lie that
18
you approached females to bring them to
19
Jeffrey Epstein?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. You are not asking me a good
23
question, sorry.
24
Q. You don't get to choose the
25
questions.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 245 of 465
Page 245
1
G Maxwell - Confidential
2
A. I would like to answer your
3
questions but you are not asking me a
4
question that I can answer.
5
Q. What about that is causing you
6
pause where you can't answer the question?
7
A. You are trying to trap me and
8
that's not fair, so I already testified that
9
I hire people across the board, so I would
10
hire architects, decorators, pool people,
11
exercise instructors, gardeners, cooks,
12
chefs, cleaning people. So I, in the course
13
of a very long time when I would hire people
14
I hired people to work for Jeffrey. So I'm
15
happy to testify to hiring people for every
16
possible conceivable proper job that you
17
could conceive of within the context of
18
Jeffrey's life and homes.
19
Q. Is it a lie that you approached
20
females to bring them to Jeffrey Epstein for
21
the purpose of performing massages?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Again, I have already testified
25
that part of the job that I had was to hire



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 246 of 465
Page 246
1
G Maxwell - Confidential
2
lots of different types of people. In terms
3
of whatever -- very small part of my job,
4
Jeffrey enjoyed getting massages. I think
5
that is something we can all agree in this
6
room and within the context of that, very
7
infrequently I would go to spas and myself
8
happily receive a professional nonsexual
9
massage from a man and/or from a woman and if
10
that massage was something that I thought was
11
something that was good, I would ask if that
12
man or woman would come back and does home
13
visits. If that person said that they did,
14
they would sometimes come, from time to time,
15
not always, come back to the house to perform
16
a nonsexual professional male or female
17
massage.
18
Q. Were any of the exercise
19
instructors you hired under the age of 18?
20
A. Again, I don't hire, we've already
21
established that I don't hire people. I
22
interview people to see if they are competent
23
in the job that they do and/or whether they
24
are someone who seemed that they can do home
25
visits.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 247 of 465
Page 247
1
G Maxwell - Confidential
2
At the point where I think that
3
there is somebody that has, can be either
4
whatever the job may be, pool, gardener, chef
5
and/or exercise instructor and I think they
6
could be good at whatever it is at whatever
7
skill that they had and they did a home visit
8
which would obviously be mandatory and Mr.
9
Epstein would meet with them and decide if he
10
wanted to have whatever skill it was that he
11
would do it and then he would then either
12
have them come back or hire them.
13
Q. Were there any exercise instructors
14
that worked at the home that were under the
15
age of 18?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. Again, I keep coming back to this,
19
that the people that I employed or -- not the
20
right word, the people I would meet to come
21
and work at the house, under any guise
22
whatsoever, again, from any of the many
23
positions that I filled, were all over --
24
were adults.
25
Q. When you say adults, over the age



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 248 of 465
Page 248
1
G Maxwell - Confidential
2
of 18?
3
A. I think we can establish what adult
4
would be.
5
Q. You never interviewed or I know you
6
don't want to use the word hired, whatever
7
your role was, you brought in an exercise
8
instructor that was under the age of 18 to
9
work at the house?
10
MR. PAGLIUCA: Object to the form
11
and foundation.
12
A. I have already testified that what
13
I was responsible for was to find people who
14
had competencies in whatever area I was
15
looking for. The competencies I was looking
16
for were professional and adult.
17
Q. So there was no exercise instructor
18
that worked at the Palm Beach house or the
19
New York house or the New Mexico house or the
20
USVI under the age of 18?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. I can only testify to when I was at
24
the house.
25
Q. Yes.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 249 of 465
Page 249
1
G Maxwell - Confidential
2
A. I can only testify to the years
3
when I was present.
4
Q. Right.
5
A. And I can also only testify to
6
people I personally either met and/or worked
7
with and/or invited, to find the correct
8
word, I don't know what the correct word is,
9
to come to do exercise or whatever it was at
10
the house.
11
Of the people that I, male and/or
12
female that I brought were all appropriate
13
and age appropriate adults.
14
Q. Over the age of 18?
15
A. We've established them as an adult.
16
Q. You are saying appropriate adults,
17
so we are clear, you didn't hire or bring in
18
or know of any exercise instructors that were
19
under the age of 18 at any of those homes?
20
A. I am also testifying that when I
21
was present at the house and with the people
22
that I brought in, were all age appropriate
23
adults.
24
Q. How do you define age appropriate
25
adults, is that over the age of 18, can we



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 250 of 465
Page 250
1
G Maxwell - Confidential
2
agree to that?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
Q. Are they under the age of 18?
6
A. We already established that you can
7
be a masseuse in Florida at age 17. That
8
does not make it inappropriate.
9
A. I'm not saying appropriate or
10
inappropriate. I'm just asking if there were
11
any exercise instructors that were under the
12
age of 18.
13
A. I am not aware if anybody was but I
14
don't want to full out and say you oh she
15
said, we already established you can be a 17
16
year old masseuse and have it not be
17
something that is not appropriate. So when
18
you say that and then you go, well, you come
19
back and say something, now we can establish
20
that Virginia was 17 but you can be a 17 year
21
old legal masseuse, but I am not aware to
22
your point.
23
Q. Who were the other 17 year old
24
masseuses that you were aware of?
25
A. I am not aware of any.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 251 of 465
Page 251
1
G Maxwell - Confidential
2
Q. Were there any 16 year year old
3
masseuse that you are aware of?
4
A. I am not aware.
5
Q. Any 15?
6
A. I just want to be clear. The only
7
person that I am aware of who claims to have
8
been a -- we have to -- we established
9
Virginia now is 17, given she has changed her
10
age so many times. The only person that I am
11
aware of that was a masseuse at the time when
12
I was present in the house was Virginia.
13
Q. Is it an obvious lie that Jeffrey
14
Epstein had a sexual preference for underage
15
miners?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. Can you ask the question again?
19
Q. It is it an obvious lie that
20
Jeffrey Epstein had a sexual preference for
21
underage minors?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Can you ask the question again?
25
Q. Is it an obvious lie that Jeffrey



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 252 of 465
Page 252
1
G Maxwell - Confidential
2
Epstein had a sexual preference for underage
3
minors?
4
MR. PAGLIUCA: Object to the form
5
and foundation.
6
A. I cannot testify to what
7
Jeffrey's --
8
Q. You don't know his preference?
9
A. You handed me a stack of papers
10
from the police reports and that's what I've
11
read but I have no knowledge, direct
12
knowledge, of what you are referencing.
13
Q. So you don't know, you don't know
14
in your own mind that Jeffrey Epstein had a
15
sexual preference for underage minors, is
16
that correct?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
Q. Is that correct?
20
A. Please ask the question again.
21
Q. You don't know in your own mind
22
that Jeffrey Epstein had a sexual preference
23
for underage minors?
24
MR. PAGLIUCA: Objection to the
25
form and foundation. You have to pause,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 253 of 465
Page 253
1
G Maxwell - Confidential
2
let me object, answer the question.
3
Listen to her question, pause, I object,
4
you answer.
5
Q. So you don't know in your own mind
6
that Jeffrey Epstein had a sexual preference
7
for underage minors?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
Q. You can answer.
11
A. I cannot tell you what Jeffrey's
12
story is. I'm not able to.
13
Q. Did Jeffrey Epstein have a scheme
14
to recruit underage girls to use them for
15
purposes of sexual massages?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. Can you ask me again, please?
19
Q. Did Jeffrey Epstein have a scheme
20
to recruit underage girls to recruit them for
21
sexual massages?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. Can you ask it a different way?
25
Q. Did Jeffrey Epstein have a scheme



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 254 of 465
Page 254
1
G Maxwell - Confidential
2
to recruit underage girls for sexual
3
massages?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
Q. If you know.
7
A. I don't know what you are talking
8
about.
9
Q. Is it an obvious lie that Virginia
10
Giuffre was a minor the first time she was
11
taken to Jeffrey Epstein's house?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. So we've already established that
15
Virginia was 17 and we have established that
16
her mother brought her to the house and that
17
she came as a masseuse, age 17, which is
18
legal in Florida.
19
Q. Would Jeffrey Epstein's assistants
20
arrange times for underage girls to come to
21
the house for sexual massages?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. What are you talking about?
25
Q. Sure. Would Jeffrey Epstein's



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 255 of 465
Page 255
1
G Maxwell - Confidential
2
assistants, I think earlier you mentioned, we
3
talked about
who worked in the
4
role as an assistant or
.
5
Would Jeffrey Epstein's assistants arrange
6
times for underage girls to come over the
7
house for sexual massages?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. Again, I read the police reports so
11
this is all happening according to the police
12
reports when I am no longer at the house so I
13
can't testify to what Jeffrey's assistants
14
did when this kind of activity as alleged in
15
the reports.
16
Q. So you don't know?
17
A. No.
18
Q. Would Jeffrey Epstein's assistants,
19
meaning
or any
20
other assistant that you are aware of from
21
the time you worked there take nude
22
photographs of underage girls?
23
MR. PAGLIUCA: Object to the form
24
and foundation.
25
A. During what period of time?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 256 of 465
Page 256
1
G Maxwell - Confidential
2
Q. During any period of time you
3
worked, did you observe that?
4
A. I did not observe any such
5
photographs.
6
Q. Are you aware if they took those
7
kinds of photos?
8
A. I am not aware.
9
MR. PAGLIUCA: Can we take a
10
five-minute break.
11
THE VIDEOGRAPHER: It's 2:58 and we
12
are off the record.
13
(Recess.)
14
THE VIDEOGRAPHER: It's now 3:10.
15
We're starting disk No. 6 and we are
16
back on the record.
17
Q. Ms. Maxwell, was it an obvious lie
18
when Virginia said she was sent to Thailand
19
by Epstein in September of 2002?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I have no knowledge of Virginia
23
being sent to Thailand.
24
But may I say something?
25
Q. There is not a question pending



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 257 of 465
Page 257
1
G Maxwell - Confidential
2
unless you want to clarify something.
3
Did you want to clarify that?
4
A. No, I just wanted to say something.
5
Q. Is it an obvious lie when Virginia
6
said she was given instructions to maintain
7
telephone contact with you while she was in
8
Thailand?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. Can you repeat the question?
12
Q. Is it an obvious lie when Virginia
13
said she was given instructions to maintain
14
telephone contact with you when she was in
15
Thailand?
16
MR. PAGLIUCA: Same objection.
17
A. I have no idea what instructions
18
Virginia was given, if any, when she went to
19
Thailand.
20
Q. So you know she went to Thailand?
21
A. I know she claimed she went to
22
Thailand from having read it but given that
23
she lied about everything it's hard to know
24
what is true and not true.
25
Q. Would it make any sense for her to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 258 of 465
Page 258
1
G Maxwell - Confidential
2
be in contact with you, would there be any
3
reason why she needed to be in contact with
4
you?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. When are we talking about?
8
Q. When she went to Thailand.
9
MR. PAGLIUCA: Same objection.
10
Q. In 2002, would there be any reason
11
for her to remain in contact with you?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. Can you ask the question again,
15
please?
16
Q. Would there be any reason for
17
Virginia to maintain contact with you in 2002
18
when she went to Thailand?
19
MR. PAGLIUCA: Same objection.
20
A. First of all, I didn't know that
21
she went to Thailand. I had had nothing to
22
do with her trip to go to Thailand and there
23
would absolutely no reason for her to be in
24
touch with me, whatsoever.
25
Q. Did you ever have a phone number



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 259 of 465
Page 259
1
G Maxwell - Confidential
2
that was
3
A. I did.
4
Q. Was that a cell phone number?
5
A. Yes.
6
Q. Is that your current cell phone
7
number?
8
A. Yes.
9
Q. I'm going to mark a couple of
10
things here?
11
(Maxwell Exhibit 11, photos, marked
12
for identification.)
13
THE WITNESS: Can I say something
14
now?
15
MR. PAGLIUCA: No.
16
THE WITNESS: Will you let me know
17
when I can?
18
MR. PAGLIUCA: When she asks you a
19
question:
20
Q. So we've marked this as Exhibit 11.
21
I'm showing you what's been marked as Exhibit
22
11 which is Giuffre 003191 and 003192.
23
Can you take a look at that
24
document for me. Is that number that you
25
just identified the
as being



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 260 of 465
Page 260
1
G Maxwell - Confidential
2
your cell phone number, is that number on
3
this document?
4
A. It is.
5
Q. And do you know who authored this
6
document?
7
A. I do not.
8
Q. Who is
9
A. I don't know who
is on this
10
document because I don't know what this
11
document is.
12
Q. Do you know someone by the name of
13
14
A. I do know someone by the name of
15
16
Q. Would he know your phone number?
17
MR. PAGLIUCA: Object to the form.
18
A. I have to idea.
19
Q. Why would Virginia be instructed to
20
call Ms. Maxwell at your number on this form?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. I don't know what this document is.
24
I don't know when it was done, I don't know
25
anything about it other than I can see it has



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 261 of 465
Page 261
1
G Maxwell - Confidential
2
my name and my number on it.
3
Q. So
-- you said
-- is he
4
employed by Mr. Epstein?
5
A. Again, it is not the only one
6
on the planet.
7
Q. I understand.
8
Do you know a
that is employed
9
by Mr. Epstein?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. Can you ask me the question again?
13
Q. Do you know someone by the name of
14
that was employed by Mr. Epstein back in
15
2002?
16
A. I do know somebody who was employed
17
by Mr. Epstein known as
18
Q. Do you recognize the other numbers
19
listed at the top of this document?
20
A. I do not.
21
Q. Would you have known
cell
22
number at that time in 2002?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. I have no idea.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 262 of 465
Page 262
1
G Maxwell - Confidential
2
Q. Can I ask you to turn to the next
3
page, please.
4
Do you know who
5
is who is mentioned on this document?
6
A. I do not.
7
Q. If you look on the bottom lines of
8
the document, it says, Still in Thailand
9
during your stay, if she is, she will be
10
staying at the same hotel.
11
Do you recall ever giving Virginia
12
instructions to meet a girl in Thailand?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I have already testified that I
16
didn't even know that Virginia was going to
17
Thailand.
18
Q. So you didn't give her instructions
19
to meet a girl in Thailand?
20
A. Like I said, I didn't even know she
21
was going to Thailand.
22
Q. Do you know whether Jeffrey Epstein
23
would have given her instructions to meet a
24
girl in Thailand?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 263 of 465
Page 263
1
G Maxwell - Confidential
2
form and foundation.
3
A. I cannot possibly tell you what
4
Jeffrey did or didn't do. I wouldn't know.
5
Q. Do you know whether Jeffrey Epstein
6
paid for Virginia to go to Thailand?
7
A. Again, I wouldn't know if he did.
8
(Maxwell Exhibit 12, documents,
9
marked for identification)
10
Q. I'm going to direct -- you can take
11
a look at it and then I'm going to direct
12
your attention to a couple of pages.
13
MR. PAGLIUCA: So the record should
14
be clear, this exhibit which is 12 is
15
375, 6, 7, 8, 9, 80, 1, and then skips
16
to 919, 920, 921, 922, 923, 924, 925 and
17
926.
18
Q. So I'm going to direct your
19
attention to the first page, have you ever
20
traveled with Jeffrey Epstein where you've
21
received a document like this from Shoppers
22
Travel in your own independent travel.
23
Do you recognize this?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 264 of 465
Page 264
1
G Maxwell - Confidential
2
Q. The front form, the front page, do
3
you recognize this Shopper Travel form, have
4
you ever used them as a travel agent with
5
Jeffrey Epstein?
6
MR. PAGLIUCA: Same objection.
7
Q. You can answer.
8
A. I don't recognize this.
9
Q. Turning to the second page which is
10
the 00376, do you see at the top of that
11
document where it says Jeffrey Epstein, J.
12
Epstein 457 Madison Avenue 4th floor New York
13
New York.
14
Is that an address you are familiar
15
with that is Jeffrey Epstein's?
16
A. I am.
17
Q. Do you see below that, travel on
18
Singapore Airlines, and you are going to have
19
to go from New York JFK to Singapore Bangkok.
20
Do you see that?
21
MR. PAGLIUCA: What?
22
Q. The first entry is going to be on
23
September 27, New York.
24
MR. PAGLIUCA: I see it.
25
MS. McCAWLEY: I'm not talking to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 265 of 465
Page 265
1
G Maxwell - Confidential
2
you. I'm talking to the witness.
3
A. I see it.
4
Q. To Singapore Bangkok?
5
A. Singapore Bangkok I'm afraid are
6
not the same place.
7
Q. Singapore, then Bangkok:
8
Q. I'm going to turn you to page
9
Giuffre, it's a little further back 000919.
10
And do you see at the top where it says J.
11
Epstein, underneath, Royal Princess, change
12
mine?
13
A. I do.
14
Q. Does this refresh your recollection
15
that Virginia Roberts' trip to Thailand was
16
paid for by Jeffrey Epstein?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I can only testify to the piece of
20
paper you showed me that has that
21
information. I cannot testify from direct
22
memory.
23
Q. When Virginia was traveling to
24
Thailand, which the dates, again, I'm going
25
to refer you back to the first page so you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 266 of 465
Page 266
1
G Maxwell - Confidential
2
can see the dates.
3
MR. PAGLIUCA: Can you identify a
4
Bates number, please.
5
Q.
which was at the top says,
6
. I'm going to refer you,
7
at the same time, to the flight logs which
8
were marked, the thicker document that looks
9
like this with all the log entries on it.
10
I'm going to refer you to page --
11
MR. PAGLIUCA: That's Exhibit No.
12
6, correct? I'm trying to keep the
13
record straight.
14
MS. McCAWLEY: I don't have Exhibit
15
numbers on mine. That's Giuffre
.
16
MR. PAGLIUCA: Hang on one second.
17
A. Can you repeat the number please.
18
Q.
. And if you will look on
19
that page at the entry, under
20
starting with the
and then it runs
21
down to the, looks like the
that first
22
entry has
,
23
, Jeffrey Epstein and the
24
initials GM.
25
Do you remember taking a trip with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 267 of 465
Page 267
1
G Maxwell - Confidential
2
during
?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. Can you repeat the question,
6
please?
7
Q. Do you remember taking a trip with
8
during
9
that's the
it looks like, through the
10
11
A. I don't remember the dates. I
12
couldn't testify to when we actually did it
13
but I do remember the trip itself.
14
Q. So you were traveling with Jeffrey
15
Epstein and
at the same
16
time Virginia was headed to Thailand, is that
17
correct?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I don't know, is that right?
21
Q. If you look at
on the
22
document that I gave you, the first document
23
and then you referred to, if you look in the
24
same as above lines, you will see the travel
25
group with
?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 268 of 465
Page 268
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Are you asking her
3
to compare the documents or are you
4
asking her what her personal knowledge
5
is.
6
MS. McCAWLEY: I'm asking if she can
7
look at the doubts and tell me if she
8
recalls that she traveling with
9

at the same time this
10
document reflects Virginia was in
11
Thailand.
12
A. I can't testify to any dates. I
13
couldn't tell you. I can see a date and I
14
can see a date but I can't tell you that I
15
have a memory of the dates. I have a memory
16
of the trip, I don't have a memory of the
17
time.
18
Q. Who is
?
19
A.
20
Q. What is her address?
21
A. I don't know.
22
Q. Does she live in the United States?
23
A. She does.
24
Q. In what state?
25
A. I believe in New Jersey somewhere.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 269 of 465
Page 269
1
G Maxwell - Confidential
2
Q. Do you have her phone number?
3
A. Not memorized.
4
Q. Do you have the ability to get her
5
phone number?
6
A. Of course.
7
Q. Has she ever asked -- has
8
ever asked other girls to come over to
9
see Jeffrey Epstein for the purpose of a
10
sexual massage?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. Can you ask the question again
14
please.
15
Q. Has
ever asked girls to
16
come over to see Jeffrey Epstein for the
17
purpose of a sexual massage?
18
MR. PAGLIUCA: Object to form and
19
foundation.
20
A. Can you ask again, please?
21
Q. Has
ever asked girls to
22
come over to see Jeffrey Epstein for the
23
purpose of sexual massage?
24
A. I have no personal knowledge.
25
Q. What does
do for you?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 270 of 465
Page 270
1
G Maxwell - Confidential
2
A. She helps with my not-for-profit
3
ocean foundation and any other related
4
activities that I may have.
5
Q. Is she paid for by Jeffrey Epstein?
6
A. No.
7
Q. She is paid for by you?
8
A. Yes.
9
Q. When did you first meet
10
11
A. I don't recollect exactly, sometime
12
maybe 2002, 2003.
13
Q. How did you meet her?
14
A. I don't recollect exactly how we
15
met.
16
Q. Did Jeffrey introduce you to her?
17
A. I don't recollect how we met.
18
Q. Does she know Jeffrey Epstein?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. Can you ask again, please?
22
Q. Does
know Jeffrey
23
Epstein?
24
A. What do you mean by know?
25
Q. Has she met her him before?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 271 of 465
Page 271
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I can't recollect a time when
5
-- I've seen
with Jeffrey but --
6
Q. You are not sure --
7
A. I know they know either other. I
8
can't testify to a meeting between them.
9
Q. Do you know where in New Jersey she
10
lives?
11
A. No
12
Q. You don't know a city?
13
A. No.
14
Q. How long has she worked for you?
15
A. Sometime 2002, 2003.
16
Q. To the present?
17
A. Yeah.
18
Q. Why do you think that
19
might know Jeffrey?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. Because you know, I know Jeffrey.
23
Q. Have you seen them together?
24
A. I already testified I have not seen
25
them together, to my recollection.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 272 of 465
Page 272
1
G Maxwell - Confidential
2
Q. Is it your testimony that
3
knows Jeffrey Epstein through the work
4
that she does for you?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I don't recollect, and I don't
8
recollect how I met
and I can't testify
9
to what
relationship is or is not with
10
Jeffrey.
11
Q. Have you ever talked to Jeffrey
12
about
13
A. I don't know what you mean.
14
Q. In any way, have you ever had a
15
conversation with Jeffrey about
?
16
A. In what context.
17
Q. In any context. Have you ever
18
talked to Jeffrey Epstein about
?
19
A.
works for me so it's entirely
20
possible that in the course of conversations
21
since 2002, 2003 that a conversation in which
22
name would have come up is entirely
23
possible.
24
Q. I provided you with and I'm sorry,
25
I don't know all the numbers, but the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 273 of 465
Page 273
1
G Maxwell - Confidential
2
statement that was issued by
that
3
should be a single page still in your stack
4
of exhibits there.
5
MR. PAGLIUCA: Exhibit 10.
6
Q. Did you authorize
to issue
7
that statement on your behalf in January of
8
2015?
9
A. I already testified that that was
10
done by my lawyers.
11
Q. So did you authorize your lawyers
12
to issue a statement on your behalf through
13
in January of 2015?
14
A. It was determined that I had to
15
make a statement in the United Kingdom
16
because of the appalling lies and I just
17
thought of some new ones.
18
Virginia's statement that I
19
celebrated her 16 birthday with her. We can
20
all agree that that's entirely impossible. I
21
didn't meet her until she was 17 and other
22
lies she perpetrated that she had a diary and
23
we all know is a complete fake. That's not a
24
diary. It was just a book she was writing
25
that you helped sell to the press, as if it



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 274 of 465
Page 274
1
G Maxwell - Confidential
2
was a diary, when it was just a story that
3
she is writing of fiction, fictional story
4
for money.
5
Q. How did you arrive at the words
6
that were put in that statement?
7
MR. PAGLIUCA: I'm going to object
8
and instruct you to the extent this
9
calls for any privileged communications
10
between yourself and
or
11
another lawyer representing you, we're
12
asserting privilege. If you can answer
13
that without that, feel free to answer.
14
Q. So what your counsel is saying, and
15
I will exclude any privileged communications
16
you had with your lawyers.
17
The question is, how did you arrive
18
at the words that were put in that statement,
19
if you can tell me without disclosing
20
privileged communications?
21
A. I'm not sure that I can.
22
Q. Is the statement that you issued
23
true?
24
A. What do you mean by that?
25
Q. Is the statement that you issued,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 275 of 465
Page 275
1
G Maxwell - Confidential
2
the statement that's in front of you, is it a
3
true statement?
4
A. As in that Virginia is a liar?
5
Q. The words you put in there, is that
6
true?
7
A. Of course they're true.
8
Q. When did you become aware that the
9
statement was being released?
10
A. I don't recollect exactly.
11
Q. What day it was?
12
A. No.
13
Q. I'm sorry. Did you identify, I
14
might not have caught it, did you identify
15
the name of the lawyer that you said you
16
retained for purposes of this statement?
17
A. I think
.
18
Q. Did you pay that lawyer
19
20
A. Yes.
21
Q. Are you aware of any interstate or
22
international transportation of a woman aged
23
18 to 28 for the purposes of prostitution?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 276 of 465
Page 276
1
G Maxwell - Confidential
2
A. I'm not sure I even understand your
3
question.
4
Q. I will go slower.
5
Are you aware of any interstate,
6
meaning between states, or international,
7
meaning oversees transportation, of women
8
aged 18 to 28, for the purposes of
9
prostitution?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. Are you asking -- I'm still not
13
sure I understand the question.
14
Q. I will try to make it clearer.
15
I'm asking you if you are aware of
16
any interstate, meaning between states, or
17
international transportation, meaning by
18
flight or by car or by train, of women aged
19
18 to 28, their ages are between the ages of
20
18 and 28, for the purposes of prostitution?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. In the world I'm sure that that
24
happens, I read about it all the time.
25
Q. Not in the world. Are you aware of



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 277 of 465
Page 277
1
G Maxwell - Confidential
2
it, in your experience with Jeffrey Epstein,
3
of any interstate or international
4
transportation of women aged 18 to 28, for
5
the purposes of prostitution?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. So whilst I appreciate this might
9
not seem like a smart question, what do you
10
mean by prostitution, what are you asking me
11
exactly?
12
Q. That would be sex for hire, any
13
kind of sexual act that's paid for.
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
A. Who's paying, what are you asking
17
me.
18
Q. It can be paid for by anybody.
19
It's a sexual act that's paid for.
20
I'm asking if you are aware of any
21
interstate or international transportation of
22
women aged 18 to 28, for the purposes of
23
prostitution?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 278 of 465
Page 278
1
G Maxwell - Confidential
2
A. I have no idea what you are talking
3
about.
4
Q. So you are not aware of that?
5
A. No.
6
Q. Are you aware of any interstate or
7
international transportation of women, aged
8
18 to 28, for the purposes of having sex with
9
Epstein where they would receive compensation
10
of any type?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I don't know what you are referring
14
to.
15
Q. Do you want me to repeat the
16
question?
17
A. Sure, go ahead.
18
Q. Are you aware of any interstate or
19
international transportation of woman, aged
20
18 to 28, for the purpose of having sex with
21
Jeffrey Epstein where they would receive
22
compensation of any type?
23
MR. PAGLIUCA: Objection to form
24
and foundation.
25
A. I am not aware of what you are



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 279 of 465
Page 279
1
G Maxwell - Confidential
2
talking about.
3
Q. Are you aware of any interstate or
4
international transportation of women, aged
5
18 to 28, for the purposes of providing a
6
massage for Jeffrey Epstein?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. So I you need to repeat that
10
question for me.
11
Q. Sure.
12
Are you aware of any interstate,
13
meaning between states, or international,
14
oversees, transportation of women, aged 18 to
15
28, for the purposes of providing massage for
16
Jeffrey Epstein?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I think we can agree he did travel
20
from time to time with a professional adult
21
masseuse.
22
Q. Are you aware of any interstate or
23
international transportation of women, aged
24
18 to 28, for the purposes of providing a
25
massage to any person other than Jeffrey



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 280 of 465
Page 280
1
G Maxwell - Confidential
2
Epstein?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. Again, I'm not aware of anybody
6
that, if you are asking for specifics to
7
someone else, I have no knowledge of that.
8
Q. So you are not aware of any
9
interstate or international transportation of
10
a woman aged 18 to 28 for the purposes of
11
providing a massage to any person other than
12
Jeffrey Epstein?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I don't recall what any single
16
person being on a plane for a massage with
17
someone else other than Jeffrey, for the sole
18
purpose, if that's the question, I don't have
19
any recollection of that.
20
Q. Earlier in your testimony, you
21
stated that Virginia Roberts was 17 at the
22
time you met her.
23
How do you know she was 17?
24
MR. PAGLIUCA: Objection to the
25
form and foundation. And to the extent



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 281 of 465
Page 281
1
G Maxwell - Confidential
2
that calls for a privileged response,
3
I'm instructing you not to answer.
4
Q. How do you know Virginia Roberts
5
was 17 at the time you met her?
6
MR. PAGLIUCA: Again, if you
7
learned that information from your
8
lawyer, I'm instructing you not to
9
answer.
10
A. I will follow my counsel's advice.
11
Q. Are you able to answer that
12
question without telling me information you
13
learned from a lawyer?
14
A. I'm not.
15
Q. So you don't have independent
16
knowledge that Virginia, according to your
17
statement, was 17 at the time you met her?
18
A. Again, my lawyer has instructed me
19
not to answer.
20
Q. I'm asking you a different
21
question. Whether you have any independent
22
knowledge, outside your lawyers, that
23
Virginia was 17 at the time you met her?
24
A. Following the instructions of my
25
lawyers, I can only remember or testify to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 282 of 465
Page 282
1
G Maxwell - Confidential
2
what she --
3
MR. PAGLIUCA: She is asking you a
4
different question. She is asking other
5
than what your lawyers have told you, do
6
you have any knowledge about her being
7
17, that's what she is asking.
8
A. I can't recollect where I got all
9
the information that I have that definitively
10
shows that.
11
Q. Earlier in your testimony, I
12
believe you said all of us would know that
13
Virginia was 17 at the time you met her.
14
How would we know that?
15
A. I think you know that by her own
16
dates, now that it was in 2000, so her entire
17
tail of me celebrating her 16th birthday is
18
clearly another giant falsehood.
19
Q. But she was 16 and 17 that year,
20
wasn't she?
21
A. Which year?
22
Q. You said it was 2000.
23
A. I think the information that I have
24
that indicates that definitively was
25
something that is privileged, so I can't



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 283 of 465
Page 283
1
G Maxwell - Confidential
2
share with you.
3
Q. So you have privileged information
4
that definitively tells you that she was 17
5
at the time you met her?
6
A. I believe I do.
7
Q. How would we know that?
8
A. What are you asking me?
9
Q. Earlier today you testified that we
10
would know that she was 17 at the time that
11
you met her.
12
How would we know that?
13
A. I imagine you have access to
14
exactly the same information that I do.
15
Q. What is that information?
16
A. Again, it's privileged, I can't
17
share it with you but you have been on this
18
case for, I don't know, much much longer than
19
I have and I imagine you have all the
20
information that I do.
21
Q. Do you know whether your lawyers
22
have produced documents from you that would
23
show the age that Virginia was at the time
24
that you met her?
25
MR. PAGLIUCA: To the extent that



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 284 of 465
Page 284
1
G Maxwell - Confidential
2
calls for a communication that you had
3
with one of your lawyers, I'm
4
instructing you not to answer that
5
question.
6
Q. I assume you, as part of the
7
discovery process, had to collect documents
8
that were relevant to this action, is that
9
correct?
10
A. I did.
11
Q. Did you collect documents that
12
would show that Virginia was 17 at the time
13
that you met her?
14
A. I think you have everything that
15
relates, that I had, contemporaneously per
16
what you asked for that I have that relates
17
to that.
18
Q. Did you have a document that
19
identified that Virginia was 17 at the time
20
that you met her?
21
A. You have all of the documents that
22
I had.
23
Q. I'm not asking what documents. I'm
24
asking, do you have a document that
25
identifies Virginia being 17 at the time you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 285 of 465
Page 285
1
G Maxwell - Confidential
2
met her?
3
A. You have every document that I
4
have. You have seen every document that I
5
have.
6
Q. That's not what I'm asking.
7
A. I don't recall every document that
8
I gave you, so I don't know. I would have to
9
look at every single document I gave you and
10
then review it but as I recall you have every
11
document that I have.
12
Q. What are you planning to show the
13
jury that will prove that Virginia was 17
14
when you met her?
15
A. Again that's privileged so I can't
16
share that with you.
17
Q. If you're showing the jury, it
18
wouldn't be privileged, so is there a
19
document you have produced in this matter
20
that shows that Virginia was 17 at the time
21
you met her?
22
MR. PAGLIUCA: She answered that
23
question already. She said she doesn't
24
know, she has given you everything. If
25
there is a decision -- assuming for the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 286 of 465
Page 286
1
G Maxwell - Confidential
2
moment there is such a document, just
3
hypothetically, and assuming for the
4
moment that it is going to get produced
5
somewhere, if it hasn't already been
6
produced, obviously that would involve a
7
waiver, a future waiver of the
8
privilege. I think that's the answer to
9
the question.
10
Q. Has the document been produced, do
11
you know?
12
A. You have everything that I have
13
given you, so if you can't -- if it's not in
14
those documents, I don't know what to tell
15
you.
16
Q. Your lawyers haven't withheld any
17
documents?
18
A. They are right here. You can ask
19
them.
20
Q. I'm asking you.
21
A. I don't know what -- they're
22
lawyers.
23
Q. When we were talking earlier about
24
, I asked you whether you had
25
ever given him a gift of a puppet.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 287 of 465
Page 287
1
G Maxwell - Confidential
2
Did you ever, not as a gift, did
3
you ever see in the presence of
4
a puppet?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. Can you be more direct, please?
8
Q. Sure. Were you ever in a room with
9
where there was a puppet?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. Can you be more specific please and
13
can you bound it by time and be more
14
specific, whatever you are actually asking
15
me?
16
Q. Were you ever in a room with
17
in New York in Jeffrey Epstein's home
18
where there was a puppet?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. What sort of puppet are you asking
22
me?
23
Q. Any kind of puppet?
24
A. You need to be more descriptive. I
25
don't know what you mean by puppet, there is



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 288 of 465
Page 288
1
G Maxwell - Confidential
2
hand puppets, all sorts of puppets.
3
Q. Is there any puppet you've ever
4
seen in Jeffrey Epstein's home in the
5
presence of
6
A. Again, puppet, you know, there is
7
lots of types of puppets.
8
Q. Any type of puppet.
9
A. If you want to give me a
10
description of the puppet, I would be perhaps
11
be able to say.
12
Q. Any type of puppet?
13
A. Can you be more detailed?
14
Q. Have you ever seen a puppet in
15
Jeffrey Epstein's home in the presence of
16
?
17
A. My understanding of a puppet is a
18
small handheld item you have in a circus. I
19
have never seen that.
20
Q. Have you ever seen a puppet which
21
is defined as a movable model of a person or
22
animal that is used in entertainment and
23
typically moved either by strings or
24
controlled from above or by a hand inside it?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 289 of 465
Page 289
1
G Maxwell - Confidential
2
form and foundation.
3
A. I have not seen a puppet that fits
4
exactly that description.
5
Q. Have you seen any puppet that fits
6
any description?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. Can you reask the question, please?
10
Q. Yes.
11
Have you seen any puppet that fits
12
any description in the presence of
in Jeffrey Epstein's home?
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
A. I am not aware of any small
17
handheld puppet that was there. There was a
18
puppet -- not a puppet -- there was a -- I
19
don't know how would you describe it really,
20
I don't know how would you describe it. Not
21
a puppet, I don't know how you would describe
22
it. A caricature of
that was
23
in Jeffrey's home.
24
Q. Did you use that caricature to put
25
the hand of the caricature on




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 290 of 465
Page 290
1
G Maxwell - Confidential
2
breast?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. I don't recollect. I recollect the
6
puppet but I don't recollect anything around
7
the puppet. You characterized puppet, I
8
characterize it as, I don't know, as a
9
characterization of
10
Q. Do you recollect asking Virginia
11
Roberts to sit on
lap with
12
the caricature of
?
13
A. I do not recollect that.
14
Q. What do you remember about the
15
caricature of the
caricature
16
when you were in the presence of
17
Virginia Roberts and
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I don't recollect the story as told
21
by
or Virginia. I don't even know
22
who -- I remember the caricature of
23
and I remember
but I
24
don't recall anything else around the
25
caricature.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 291 of 465
Page 291
1
G Maxwell - Confidential
2
Q. Did you give it to him?
3
A. I did not.
4
Q. Who gave it to him?
5
A. I don't think it was given to him
6
at all.
7
Q. Did he bring it?
8
A. No.
9
Q. Was it something that was at the
10
house?
11
A. As best I recollect.
12
Q. Was it something that you saw at
13
the house in advance of
14
arrival?
15
A. Again, I don't real -- I recollect
16
the caricature, I recollect
, I
17
don't recollect much else around the
18
caricature.
19
Q. Was there a party going on in the
20
house at the time you recollect the
21
caricature?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. You have to be way more specific?
25
Q. Do you remember, you said you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 292 of 465
Page 292
1
G Maxwell - Confidential
2
recollect this caricature, you recollect
3
being there. Do you recollect
4
a party going on at the time of that
5
interaction with
and the
6
caricature?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I don't recollect a party -- first
10
of all, they weren't really parties -- I
11
don't recollect a party -- I don't know what
12
you mean by party in the context of that
13
scenario.
14
Q. Who do you recollect being at the
15
home during the time
was there
16
with this caricature?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I only recollect myself with
20
I don't recollect anybody else.
21
Q. You don't recollect Jeffrey Epstein
22
being there?
23
A. Actually, no.
24
Q. You don't recollect
25
being there?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 293 of 465
Page 293
1
G Maxwell - Confidential
2
A. No.
3
Q. You don't recollect Virginia
4
Roberts being there?
5
A. No.
6
Q. It was just you and
?
7
A. I am not saying it was just me and
8
, you are asking me do you
9
remember. I only remember
, I
10
remember
and the caricature but
11
I can't place the caricature and everybody
12
else in the same context, the same timeframe
13
you are asking me.
14
Q.
18



24
MR. PAGLIUCA: Objection to the
25
form and foundation.













Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 294 of 465
Page 294
1
G Maxwell - Confidential
2
A. Typically, there is no typical
3
because there is no standard procedure, so I
4
can't comment or testify to
.
6
Q. Do you remember them being in the
7
house?
8
A. Not specifically.
9
Do you mind if I take a bathroom
10
break.
11
THE VIDEOGRAPHER: It's now 3:51
12
and we are off the record.
13
(Recess.)
14
THE VIDEOGRAPHER: It's now 4:04.
15
We are back on the record and we're
16
starting disk No. 7.
17
Q. Ms. Maxwell, during what time
18
period, I know you said, I believe you said
19
you met Jeffrey in 1991, if I'm correct there
20
and you've known him through the present.
21
During what time period within
22
those years would you say your relationship
23
was the closest with Jeffrey?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 295 of 465
Page 295
1
G Maxwell - Confidential
2
A. What do you mean by close, sorry.
3
Q. I think earlier today you testified
4
that at some point in time you considered
5
yourself to be his girlfriend, is that the
6
closest you would say that your relationship
7
was with him and if so, what time period was
8
that?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I don't think I said I was his
12
girlfriend, I would like to think of myself
13
as maybe, I don't think I -- sometime in the
14
mid '90s.
15
Q. How close was your relationship?
16
A. We were very friendly.
17
Q. Without going into details, was
18
your relationship with him intimate?
19
A. Yes.
20
Q. When was the last time you had
21
contact with Jeffrey Epstein?
22
A. What do you mean by contact.
23
Q. Either a phone call or email or
24
anything of that nature?
25
A. As best as I can recollect when



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 296 of 465
Page 296
1
G Maxwell - Confidential
2
all -- sometime last year.
3
Q. So you haven't talked to him like,
4
for example, last week you didn't talk to
5
him?
6
A. I did not.
7
Q. How many times have you had either
8
direct or indirect, meaning, in the presence
9
of him or calling or emailing, contact with
10
Jeffrey Epstein from December 30, 2014 until
11
now?
12
A. I'm sorry, can you just --
13
Q. Either in person or by phone or by
14
email, from December 30, 2014 until present.
15
A. I can't really characterize that
16
but not very much. There was a period when
17
in January when you filed your, whatever you
18
filed, where we spoke and then, since then
19
not much at all.
20
Q. Can you estimate how many emails
21
you would have sent Jeffrey from the period
22
of December 30, 2014 to the present?
23
A. Not very many at all.
24
Q. More than 20?
25
A. I really wouldn't be able to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 297 of 465
Page 297
1
G Maxwell - Confidential
2
characterize it because it wouldn't be that
3
many. I wouldn't know.
4
Q. More than 50?
5
A. It would be on the lesser side, not
6
on the more side.
7
Q. Can you give me a number?
8
A. I honestly couldn't. I would be
9
guessing.
10
Q. How many emails has Jeffrey sent
11
you from the period December 30, 2014 to the
12
present?
13
A. I would say less emails, even less
14
emails than I sent him.
15
Q. More than 20?
16
A. I would say on the lesser side.
17
Q. Less meaning 10?
18
A. I really can't recall, very little.
19
Q. When you spoke with Jeffrey in
20
January of 2015, what did he say to you?
21
A. I really couldn't remember exactly
22
what he said to me.
23
Q. Did you talk about Virginia
24
Roberts?
25
A. I'm sure we did but I couldn't



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 298 of 465
Page 298
1
G Maxwell - Confidential
2
recall the exact conversation.
3
Q. Does Jeffrey Epstein send you text
4
messages?
5
A. No.
6
Q. Do you send him text messages?
7
A. No.
8
Q. How many phone calls have you had
9
with Jeffrey Epstein since December 30, 2014?
10
A. Again, very few.
11
Q. More than five?
12
A. Probably as many as the few emails
13
that I would characterize, so just very few.
14
I mean a small number.
15
Q. Are you aware of any disagreement
16
between your views about Virginia Roberts and
17
Jeffrey's views about Virginia Roberts?
18
MR. PAGLIUCA: Object to the form
19
and foundation
20
A. I cannot speculate to his views. I
21
can only testify on my views.
22
Q. Earlier you went through the series
23
of lies. Have you talked to Jeffrey about
24
the lies and does he agree with you?
25
A. I have discussed some of the issues



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 299 of 465
Page 299
1
G Maxwell - Confidential
2
with him, I can't remember specifically which
3
ones. I just don't recall. I'm sorry.
4
Q. Do you recall him telling you that
5
he didn't agree with you on any of those?
6
A. I don't recall him saying that.
7
Q. Do you have a joint defense
8
agreement with Jeffrey Epstein?
9
A. I believe I do.
10
Q. Do you have a joint defense
11
agreement with
?
12
A. I don't believe I do.
13
Q. Earlier today in your testimony,
14
when I was asking you some questions, you
15
said that you couldn't answer but that
16
Jeffrey Epstein could answer that question.
17
Would Jeffrey Epstein be in a
18
position to confirm or deny some of the
19
obvious lies that we've discussed today?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I can't possibly testify to what
23
Jeffrey could or would say. I can't speak
24
for him.
25
Q. Would Jeffrey be able to confirm or



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 300 of 465
Page 300
1
G Maxwell - Confidential
2
deny whether he had sex with Virginia
3
Roberts?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I can't say what Jeffrey would say.
7
Q. Has he discussed that with you?
8
A. He has not.
9
Q. Would Jeffrey be able to confirm or
10
deny whether he had a sexual massage from
11
Virginia that first time she came to his
12
mansion in Palm Beach?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I cannot speak for what he would
16
say. I can only speak for what I would say.
17
So as I testified everything that she said
18
about that first meeting didn't happen so...
19
Q. Has he told that you everything
20
about that first meeting didn't happen?
21
A. I know it didn't happen because she
22
put me in that room.
23
Q. I understand you know. But has
24
Jeffrey said when you are talking about the
25
obvious lies, oh yeah, that never happened?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 301 of 465
Page 301
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I can't specifically recall that.
5
I don't know, but he has to agree with me
6
because it didn't happen.
7
Q. Can Jeffrey Epstein, would he be
8
able to confirm or deny whether he had sex
9
with underage girls?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I can't testify to what Jeffrey
13
would say.
14
Q. Can Jeffrey confirm or deny whether
15
was on Jeffrey's island?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. I can't say what Jeffrey would say.
19
I can only say what I know to be true.
20
Q. Has Jeffrey talked to you about the
21
fact whether
was on his island?
22
A. As best as I can recollect, he said
23
he was not on the island. As best as I can
24
recollect.
25
Q. Can Jeffrey Epstein confirm whether



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 302 of 465
Page 302
1
G Maxwell - Confidential
2
he and Virginia Roberts were together in the
3
presence of
?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I can't speak to what Jeffrey would
7
say.
8
Q. Has he talked to about Virginia
9
Roberts' statement that she was in the
10
presence of
?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I have not discussed individual
14
presences with Virginia. That's not -- I'm
15
only concerned with what I know to be the
16
stuff about me. So my focus has always been
17
the lies and the obvious lies as something I
18
can personally attest to. I cannot possibly
19
talk for anything else.
20
Q. Has Jeffrey Epstein said to you
21
anything along the lines of Virginia is lying
22
when she says she met
?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Again, I'm not talking about what



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 303 of 465
Page 303
1
G Maxwell - Confidential
2
she says as regards to other people. I can
3
talk to things as regards to me.
4
Q. I'm asking if Jeffrey ever said
5
that to you?
6
A. I don't recollect specific
7
conversations along those things.
8
Q. You don't recollect him saying that
9
to you?
10
A. I don't recollect him saying to me
11
that Virginia didn't meet
. I'm
12
sure that wouldn't be a conversation that we
13
would have. It doesn't effect me whether --
14
so I'm really only concerned about the lies
15
that were told as regards to me.
16
Q. Can Jeffrey Epstein confirm or deny
17
whether you sent Virginia to give
18
a massage?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I can't say what Jeffrey would say,
22
I can tell you I didn't. I can't tell you
23
what anybody else.
24
Q. Have you discussed with him
25
Virginia's allegation that she gave



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 304 of 465
Page 304
1
G Maxwell - Confidential
2
a massage?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. I didn't know that she did say
6
that.
7
Q. Do you know whether Jeffrey Epstein
8
has ever sent anybody to
to
9
perform a massage for him?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I couldn't possibly recollect
13
whether he did anything like that.
14
Q. Did you ever send anybody, not
15
Virginia, anybody else over to
16
home for a massage?
17
A. Not to the best of my knowledge.
18
Q. Do you know one of
19
friend by the name of
20
21
A. I do recollect a person of that
22
name.
23
Q. How do you know her?
24
A. I don't recollect.
25
Q. Did you meet her through Jeffrey?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 305 of 465
Page 305
1
G Maxwell - Confidential
2
A. I don't recollect.
3
Q. Do you recall when you met her?
4
A. I do not recollect.
5
Q. How many times have you seen
6
in your life?
7
A. The only reason I remember is
8
because it's an unusual name but I couldn't
9
tell you anything else.
10
Q. You didn't see her on a regular
11
basis, she wasn't one of your friends?
12
A. No.
13
Q. Was
a masseuse?
14
A. Not to my knowledge.
15
Q. Do you have knowledge of whether
16
she had a sexual relationship with Jeffrey
17
Epstein?
18
A. I have no knowledge of that.
19
Q. When was the last time you spoke
20
with her?
21
A. A very long -- I have no idea.
22
Q. Would it be years?
23
A. Yes.
24
Q. What do you remember about
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 306 of 465
Page 306
1
G Maxwell - Confidential
2
A. Nothing really.
3
Q. Do you remember what she looks
4
like?
5
A. I would just be speculating on how
6
I remember. I couldn't describe her.
7
Q. Do you recall traveling with her?
8
A. I don't.
9
Q. Did you ever go to her home?
10
A. I don't believe I did.
11
Q. Do you know where she lives?
12
A. I don't.
13
Q. Would you have met her through
14
Jeffrey Epstein?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I already testified I don't
18
recollect how I met her and I remember her
19
because her name is very unusual.
20
Q. So what's your -- what recollection
21
do you have of her, do you have a specific
22
recollection of meeting her somewhere, you
23
just don't know when that was or how do you
24
know that name
?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 307 of 465
Page 307
1
G Maxwell - Confidential
2
form and foundation.
3
A. I don't know why the name is -- I'm
4
sorry -- I can't -- I have no idea. I
5
recognize the name but that's it.
6
Q. Was
a masseuse?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. What are you asking me, I'm sorry?
10
Q. When
worked for
11
Jeffrey Epstein, did she perform massages?
12
A. I've testified that when
13
came originally, she came to answer
14
telephones. I believe at some point she
15
became a masseuse. I don't recollect when
16
and I personally had massages from
17
Q. What did
do for Jeffrey
18
Epstein, did she perform massages, anything
19
else?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. When she came she answered phones
23
and at some point, I believe, I don't have
24
any firm recollection, but I believe she went
25
to school and became a masseuse and I had



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 308 of 465
Page 308
1
G Maxwell - Confidential
2
massages from her.
3
Q. Did you ever have any sexual
4
interaction with her?
5
MR. PAGLIUCA: Object to the form
6
and foundation and I'm going to instruct
7
you if we're talking about any
8
consensual adult contact, you are not
9
allowed to answer the question.
10
Q. Did you have any sexual contact
11
with her in the presence of Jeffrey Epstein?
12
MR. PAGLIUCA: Same instruction.
13
Q. Did you have any sexual contact
14
with her in the presence of anybody other
15
than Jeffrey Epstein?
16
MR. PAGLIUCA: Same instruction.
17
Q. How many massages did you receive
18
from
19
A. I really don't recall but a fair
20
amount.
21
Q. Did the massages involve sex?
22
MR. PAGLIUCA: I'm going to
23
instruct you not to answer.
24
Q. Have you ever engaged in sex with
25
any female?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 309 of 465
Page 309
1
G Maxwell - Confidential
2
MR. PAGLIUCA: I'm going to
3
instruct you not to answer.
4
MS. McCAWLEY: I want the record to
5
reflect that Ms. Maxwell's attorney is
6
directing her not to answer this series
7
of questions.
8
MR. PAGLIUCA: It definitely does.
9
Q. Were you responsible for
10
introducing
to Jeffrey Epstein?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I already testified that I don't
14
really recall
15
Q. Were you responsible for
16
introducing
to Jeffrey Epstein?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. Again, I don't like the
20
characterization of introduction.
21
came to answer telephones.
22
Q. When did you -- were you the person
23
who brought or introduced or met
for
24
purposes of bringing her to Jeffrey Epstein's
25
home?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 310 of 465
Page 310
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. That's not how I would characterize
5
that.
6
Q. How would you characterize it?
7
A. I have testified that I'm
8
responsible for finding professional people
9
to work in the homes, age appropriate adult
10
people, so from pool attendants, to
11
gardeners, to chefs, to housekeepers, to
12
butlers, to chauffeurs and one of the
13
functions was to be able to answer the
14
telephones and in the context of finding
15
someone to answer the telephones, I did look
16
to try to find appropriate people to answer
17
the phones.
18
Q. So did you find Johanna for
19
purposes of that role?
20
A. So in the course of looking for
21
somebody to answer phones at the house,
22
Johanna was one of the people who said that
23
she was willing to answer phones.
24
Q. Did you approach her at her school
25
campus?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 311 of 465
Page 311
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to form
3
and foundation.
4
A. I honestly don't recall how, in
5
that moment, how I met
and how she
6
came to get the job but...
7
Q. Did you typically, in your work for
8
Jeffrey Epstein, would you typically go to
9
school campuses to try to find individuals to
10
work for Jeffrey Epstein?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I never -- what do you mean by
14
school? Let's characterize school.
15
Q. Any kind of school.
16
A. Obviously not. I never went to any
17
school with young people.
I believe
18
came from an adult university, as I would
19
know in England, so university, I went there
20
but I never went, as I best recollect,
21
anywhere else.
22
Q. Did you -- what university was it
23
that you went to?
24
A. I don't recall the university that
25
she went to right now.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 312 of 465
Page 312
1
G Maxwell - Confidential
2
Q. Would you visit more than one
3
university to try to find individuals to work
4
for Jeffrey Epstein?
5
A. As I recollect, I think that's, in
6
fact, the only university I went to.
7
Q. Did you go there more than once?
8
A. I think I went twice.
9
Q. Who else did you find from that
10
university, was there anybody other than
11
12
A. I don't recollect, I'm sorry.
13
Q. We are going to mark this as
14
Maxwell 13?
15
(Maxwell Exhibit 13, documents,
16
marked for identification.)
17
Q. Can you take a look at the document
18
I put in front of you, please.
19
Are you familiar with this
20
document?
21
A. I'm familiar with this actual
22
document.
23
Q. How was this document created?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 313 of 465
Page 313
1
G Maxwell - Confidential
2
A. I don't know how this document was
3
created.
4
Q. You were involved in the creation
5
of this document?
6
A. I think you can see from the date
7
that it's 2004, 2005, so no.
8
Q. You weren't involved in the
9
creation of this document.
10
Did you -- we talked earlier about
11
Mr. Epstein's house, I'm talking about the
12
Palm Beach house where you said there was a
13
computer on the desk, that employees had
14
access to -- people who worked for Jeffrey
15
Epstein may have had access to?
16
A. I think anybody could have had
17
access to that.
18
Q. Was that computer used, if you know
19
to keep a log of addresses and phone contact
20
information for Jeffrey Epstein?
21
A. Are we talking about when this
22
document was created.
23
Q. In general, was there, on that
24
computer during the time that you were
25
present with Jeffrey Epstein, was there a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 314 of 465
Page 314
1
G Maxwell - Confidential
2
mechanism by which you kept electronic
3
information of names and addresses of
4
individuals that he knew?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I can't testify to what was on that
8
computer or not after I was gone.
9
Q. Not when you were gone, when you
10
were there. If Jeffrey wanted to call, for
11
example, say
, would someone be
12
able to go to that computer to pull up the
13
address information and phone contact
14
information for that individual?
15
MR. PAGLIUCA: Objection to the
16
form and foundation.
17
A. I couldn't possibly say.
18
Q. Did you ever have to keep track of
19
address or phone contact information for
20
Jeffrey Epstein?
21
A. That was not my job.
22
Q. Did you ever do it?
23
A. I am not responsible for keeping
24
his numbers so that wasn't my job at all.
25
Q. But did you ever do it? I know



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 315 of 465
Page 315
1
G Maxwell - Confidential
2
it's not your job but did you ever do it, did
3
you ever keep phone contact information for
4
him?
5
A. During the course of the time we
6
were together, if he gave me a telephone
7
number, I would give it to an assistant to
8
put in the computer, I could do that.
9
Q. Would he ask you for contact
10
information for different individuals, if he
11
wanted to contact someone?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. In the course of the long period of
15
time when I was there, it certainly would be
16
possible for him to ask me for a telephone
17
number and if I had the -- I wouldn't always
18
have it -- I'm sure it happened.
19
Q. Was there a hardcopy book in
20
addition to the computer, a hardcopy book
21
that you could look for numbers that were
22
relevant to Jeffrey Epstein's life and
23
something on the computer or was it just an
24
electronic version?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 316 of 465
Page 316
1
G Maxwell - Confidential
2
form and foundation.
3
Q. Was there a hard copy book as well
4
as something on the computer or was there
5
only electronic information on the phone
6
numbers?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I can only testify to what I know
10
obviously, and I believe that this is a copy
11
of a stolen document. I would love to know
12
how you guys got it.
13
Q. I'm asking during the time you
14
worked for Jeffrey Epstein, was there a
15
hardcopy document of any kind that kept phone
16
numbers for Jeffrey Epstein, if he needed to
17
contact someone?
18
A. The stolen document I have in front
19
of me that you have is what you are referring
20
to.
21
Q. So there was, during your time when
22
you were there, there was no other, you
23
mentioned there was information on a
24
computer. Was there any hardcopy document
25
that you could refer to to find someone's



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 317 of 465
Page 317
1
G Maxwell - Confidential
2
number?
3
A. You have the stolen document in
4
front of you.
5
Q. You had access to this when you
6
worked for Jeffrey Epstein?
7
A. This is, I believe, the book that
8
was stolen, that was the hardcopy of whatever
9
was there.
10
Q. So when you were working for
11
Jeffrey Epstein, you were able to access this
12
book?
13
A. This book -- if this is what this
14
is, I believe it was, this is the stolen
15
document from his house.
16
Q. And you were able to access it when
17
you worked for him?
18
A. It was a document that was printed
19
that you could, if you needed to, look for a
20
number.
21
Q. Do you know how this book was
22
created?
23
A. No.
24
Q. When you referred to it a moment
25
ago, to a stolen document, when



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 318 of 465
Page 318
1
G Maxwell - Confidential
2
turned this document over to the
3
FBI, are you aware he described it as a
4
document that came from your computer?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I have no idea what he said or
8
didn't say, so if you want me to reference
9
something he said, you need to show it to me.
10
Q. Did you keep this document, an
11
electronic copy of it, on your personal
12
computer?
13
A. I don't recollect.
14
Q. If you had to update something, for
15
example, if there was a new number, a new
16
individual that Jeffrey had hired that you
17
were going to track, would you input that
18
information into this document on your
19
computer?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I've already testified that I'm not
23
responsible for updating and keeping these
24
records.
25
Q. Did you have this document on your



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 319 of 465
Page 319
1
G Maxwell - Confidential
2
computer, your personal computer?
3
A. I told you, I don't recollect
4
having this document on my computer.
5
Q. Do you know what computers this
6
document was on, if more than one?
7
A. I'm sorry, this is a long time ago
8
and I don't recall exactly how this was all
9
managed.
10
Q. If you didn't create this document,
11
do you know who did?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I don't.
15
Q. I'm going to direct your attention
16
to part of this document. It's towards the
17
back, it's going to be page 91 and it has
18
bates label Giuffre 001663. I'm going to
19
direct your attention to the section that
20
says, Massage Florida.
21
Did you input any of the names or
22
numbers under that section?
23
MR. PAGLIUCA: Objection to form
24
and foundation.
25
A. So this document is produced in



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 320 of 465
Page 320
1
G Maxwell - Confidential
2
2004, 2005, so, no.
3
Q. But I'm sorry, correct me if I'm
4
misunderstanding your testimony, I thought
5
you said when you were working with Jeffrey,
6
that this document existed and it was
7
something you utilized?
8
A. I can't possibly tell you what
9
numbers were added or not added subsequent to
10
my departure.
11
Q. So you can't recall if you added
12
any of these numbers?
13
MR. PAGLIUCA: Objection to the
14
form and foundation, mischaracterizes
15
the witness' testimony.
16
Q. Are there any numbers on here or
17
names that you recognize that you would have
18
entered into this section?
19
A. I already testified that I'm not
20
responsible for inputting numbers and names
21
into this so I would not be able to tell you.
22
Q. Are there any names or numbers
23
under this section, Massage Florida, that you
24
would have provided to an assistant to input
25
into this document?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 321 of 465
Page 321
1
G Maxwell - Confidential
2
A. I can't possibly say.
3
Q. Do you see under Massage Florida,
4
about halfway down the first column, do you
5
see a number that says
cell?
6
MR. PAGLIUCA: What page?
7
Q. It's 91, Bates number 001663.
8
About halfway down, it says in the first
9
column, it says
cell.
10
Do you see that?
11
A. I do.
12
Q. Would you have provided after, I
13
know you didn't hire her, Jeffrey hired her
14
but after you brought her to Jeffrey, would
15
you have given her cell phone number to an
16
assistant to input into this document?
17
MR. PAGLIUCA: Objection to form
18
and foundation.
19
A. I didn't bring her to Jeffrey, the
20
way you characterize and I would have no
21
knowledge of how this number ended up in this
22
book.
23
Q. I believe you, and I will try to
24
use your words so we are clear, you met
25
is that correct?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 322 of 465
Page 322
1
G Maxwell - Confidential
2
A. Yes.
3
Q. And then she began working for
4
Jeffrey?
5
A. Yes.
6
Q. Would you have provided whomever
7
was in charge of keeping this updated with
8
cell number so you would be able to
9
contact her if needed?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I don't know. It could have been a
13
number of different ways, it it could have
14
been Jeffrey who gave it to somebody.
15
Q. You just don't remember doing that?
16
A. I do not.
17
Q. Now, as you look -- I want you to
18
take a look at the Florida massage list, it's
19
three columns there.
20
Do you, as you look at those names
21
on the various columns, do you know the ages
22
of any of the girls in this list?
23
A. I don't know. One, I don't know
24
who all the people are on this list and I
25
certainly don't know the ages.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 323 of 465
Page 323
1
G Maxwell - Confidential
2
Q. Do you know what their
3
qualifications are?
4
A. I don't know who the people are in
5
general so of course I don't know what their
6
qualifications are.
7
Q. Do you know why Jeffrey has so many
8
masseuses listed in Florida in his book here?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. Again, this book was created post
12
my departure, so I couldn't explain why all
13
these people were here.
14
Q. When you were there, you said this
15
book existed?
16
A. Yes.
17
Q. So when you were there, were there
18
a number of masseuses listed under the
19
Florida massage?
20
MR. PAGLIUCA: Objection to the
21
form and foundation and
22
mischaracterization of the witness'
23
testimony.
24
Q. I'm asking you a question.
25
When you were there, were there a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 324 of 465
Page 324
1
G Maxwell - Confidential
2
number of masseuses listed under the Florida
3
massage section?
4
A. When I was there, I would have, of
5
course there would have been some masseuses
6
listed but I could not tell you who or how
7
many and this -- I could not possibly because
8
I wouldn't remember.
9
Q. Do you know why Jeffrey would have
10
had so many names listed under his massage
11
Florida?
12
MR. PAGLIUCA: Objection to form
13
and foundation.
14
A. I can't testify to why Jeffrey has
15
so many.
16
Q. Did he use a different masseuse
17
every day?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
Q. You can answer.
21
A. When I was there he had a massage
22
roughly every day, one masseuse, and mostly
23
he would have them at random times, so it
24
would be difficult if you just only had one
25
person, man, woman, for an adult massage, to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 325 of 465
Page 325
1
G Maxwell - Confidential
2
come and be available for whatever time it
3
was. So he would have more than one person
4
that he could call for a massage because at
5
any given time the one that he called first
6
may not have been available.
7
Q. So would it typically be a
8
different person each day that would give him
9
a massage?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. It would be, when I was there,
13
based on availability.
14
Q. Would it surprise you to learn that
15
the Federal Government found that some of the
16
girls on this list under massage Florida were
17
under the age of 18?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I can't testify to what the
21
government found or did not find because I
22
would have no knowledge of it.
23
Q. I'm asking if you would be
24
surprised by that?
25
MR. PAGLIUCA: Form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 326 of 465
Page 326
1
G Maxwell - Confidential
2
A. I have knowledge of it. I can't
3
speculate.
4
Q. On the second column, towards the
5
bottom, there is the name, it's one up from
6
the bottom, there is the name
,
7
do you know
?
8
A. I do.
9
Q. Who is she?
10
A. She was a friend of Jeffrey's.
11
Q. Is she a masseuse?
12
A. She, I don't think she was a
13
masseuse, no.
14
Q. Why would be she listed under
15
Florida massages?
16
A. An input error.
17
Q. Is this list any individual that
18
would have sex with Jeffrey?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I wouldn't have any knowledge of
22
that.
23
Q. Do you know if Jeffrey had sex with
24
?
25
MR. PAGLIUCA: Object to the form



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 327 of 465
Page 327
1
G Maxwell - Confidential
2
and foundation.
3
A. First of all, I wouldn't have any
4
knowledge of that.
5
MS. McCAWLEY: We are going to take
6
a quick break.
7
THE VIDEOGRAPHER: It's now 4:39
8
and we are off the record.
9
(Recess.)
10
THE VIDEOGRAPHER: It's now 4:54
11
and we are as back on the record
12
starting disk number 8.
13
Q. Ms. Maxwell, we were talking
14
earlier about the journal and I believe you
15
said in 2004, 2005, you were no longer
16
working and responsible for that journal, is
17
that correct?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. What are we referring to, this
21
document right here?
22
Q. Yes.
23
A. I don't know who is the author of
24
this or I can't tell you what is in here
25
versus what would have been here when I was



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 328 of 465
Page 328
1
G Maxwell - Confidential
2
around. I can't testify to that.
3
Q. Were you around in 2004, 2005?
4
A. I already testified that I was
5
there when Jeffrey's mother passed away and
6
so you know, I did visit for her passing and
7
I believe I was there for a couple of days in
8
2005.
9
Q. So if an employee of Mr. Epstein in
10
2004 said that you were the employee's direct
11
supervisor, would that be incorrect?
12
MR. PAGLIUCA: Objection to form
13
and foundation.
14
A. What employee, what's the
15
circumstances and what is the story, I don't
16
know what you are asking me.
17
Q. If
said in 2004
18
when he was hired, you were his direct
19
supervisor, would that be true?
20
A. No.
21
Q. Were you in 2004 supervising
22
23
MR. PAGLIUCA: Objection to form
24
and foundation.
25
A. I never supervised
.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 329 of 465
Page 329
1
G Maxwell - Confidential
2
Q. Did
take orders from
3
you?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. She worked for Jeffrey.
7
Q. If
said you had
8
knowledge of underage girls coming to
9
Jeffrey's home for the purpose of sex, would
10
you contend that that is truthful?
11
MR. PAGLIUCA: Objection to the
12
form and foundation of the question.
13
A. I have no idea what you are talking
14
about, I'm sorry.
15
Q. If
said that you
16
have knowledge of underage girls coming to
17
Jeffrey's home for the purpose of having
18
massages involving sex, would you say that
19
that statement is truthful?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I can't testify to what
23
said or didn't say.
24
Q. I'm saying if
said that you
25
had knowledge that there were girls coming



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 330 of 465
Page 330
1
G Maxwell - Confidential
2
over to the house that were underage for the
3
purposes of sex, would that statement be
4
true?
5
MR. PAGLIUCA: Objection to form
6
and foundation.
7
A. I can't testify to what
8
said or didn't say or what he thought.
9
Q. Did you have knowledge of underage
10
girls coming to Jeffrey Epstein's house for
11
the purpose of sex?
12
A. No.
13
Q. Earlier I believe you testified,
14
correct me if I'm wrong, that the document
15
that is in front of you, the thicker document
16
was a stolen document.
17
Do you know who stole that
18
document?
19
A. I have read that
stole the
20
document.
21
Q. And where have you read that?
22
A. I believe it was reported in the
23
press.
24
Q. Earlier we were talking about the
25
computers at Jeffrey Epstein's home. Did you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 331 of 465
Page 331
1
G Maxwell - Confidential
2
have a computer that was your computer
3
located in Jeffrey Epstein's home?
4
MR. PAGLIUCA: Objection to form
5
and foundation.
6
A. I've testified to the computer
7
already. Even when I was around, there was a
8
computer that people had access to.
9
Q. So is
telling the
10
truth when he says that he downloaded that
11
book from your computer?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. I couldn't possibly tell you what
15
did or didn't do or said or didn't
16
say.
17
Q. Was it on your computer?
18
A. I already testified I have no idea
19
where this document came from.
20
Q. Did you have a list of names of
21
individuals with contact information for
22
Jeffrey Epstein on your personal computer?
23
A. Again, that wasn't my computer. I
24
already said that was a computer that lots of
25
people would have, so I have no recollection



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 332 of 465
Page 332
1
G Maxwell - Confidential
2
of this document being on it, so I don't know
3
where this came from.
4
Q. I understand the computer at the
5
house that you're referencing. On a personal
6
computer of yours, did you have that
7
document?
8
A. I don't know where this document
9
came from, so I can't possibly say this
10
document was on any computer that I may have
11
had access to.
12
Q. On a personal computer of your own,
13
did you have lists of the phone numbers and
14
contact information relating to Jeffrey
15
Epstein?
16
A. Like everybody, I have an address
17
book but I can't possibly testify to where
18
this thing came from.
19
Q. Was it your address book or was it
20
addresses that related to Jeffrey Epstein?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. I don't know what you're asking me.
24
Q. On your personal computer, the
25
address book you are referencing, was it your



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 333 of 465
Page 333
1
G Maxwell - Confidential
2
address book with individuals you knew or was
3
it an address book for your employer, Jeffrey
4
Epstein?
5
A. Jeffrey has his situation and I
6
have no -- this is Jeffrey's, it came from
7
his home, so I can't testify to anything
8
about this in that period of time.
9
Q. So you didn't have on your computer
10
a list of contact information for individuals
11
that was related to Jeffrey Epstein?
12
A. I don't recall exactly what I had
13
back in 2004 and 2005, so I can't say what I
14
had back then that relates to his addresses,
15
I can't recall.
16
Q. So is it possible that someone
17
could have downloaded from your personal
18
computer a list of names and address that
19
were affiliated with Jeffrey Epstein?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. This didn't come from any computer
23
of mine.
24
Q. But is it possible that someone
25
could have downloaded a list of names and



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 334 of 465
Page 334
1
G Maxwell - Confidential
2
addresses affiliated with Jeffrey Epstein
3
from your computer?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I already said, I didn't have a
7
computer there, so I don't know where this
8
came from, I have no idea.
9
Q. I'm going to read to you some
10
testimony from
deposition
11
and it's on page 370 and I want to ask you a
12
question about it, if it's true or false?
13
MR. PAGLIUCA: I'm going to object
14
unless you show the witness the
15
document.
16
MS. McCAWLEY: I will pass it. We
17
are not going to mark it. We will skip
18
it.
19
Q. Did you ever tell
20
that he better watch out and better keep his
21
mouth shut with respect to what occurred at
22
Mr. Epstein's home?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. It doesn't sound like anything I



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 335 of 465
Page 335
1
G Maxwell - Confidential
2
would say.
3
Q. Did you ever threaten
4
in any way if he were to disclose
5
information he learned from his employment
6
with Jeffrey Epstein?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I'm happy to answer. No, I never
10
threatened him in any way.
11
Q. Were you concerned that he was
12
going to disclose that Jeffrey Epstein was
13
trafficking underage girls?
14
MR. PAGLIUCA: Objection to the
15
form and foundation.
16
A. First of all, there are so many
17
things wrong with that question, but I have
18
no knowledge of what you are talking about.
19
Q. Have you ever contacted or
20
instructed anyone to contact any witness in
21
this case for the purposes of threatening
22
them not to testify in this case?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. I have never called anybody with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 336 of 465
Page 336
1
G Maxwell - Confidential
2
reference to this case with any, anything you
3
just mentioned, I never threatened anyone.
4
Q. Have you ever directed anyone to
5
call any witnesses relevant to this case and
6
threaten them not to testify?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I never done such a thing.
10
Q. Did Jeffrey Epstein or you ever ask
11
any female, regardless of age, to carry
12
Jeffrey's baby for him?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
Q. Or anything along those lines?
16
MR. PAGLIUCA: Objection to the
17
form and foundation.
18
A. Can you repeat the question,
19
please?
20
Q. Did you or Jeffrey Epstein ever ask
21
any female, regardless of age, to carry
22
Jeffrey Epstein's baby for him?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. Are you asking --



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 337 of 465
Page 337
1
G Maxwell - Confidential
2
Q. To become pregnant, did you or
3
Jeffrey Epstein ever ask any female to become
4
pregnant and carry Jeffrey Epstein's baby for
5
you or for Jeffrey?
6
MR. PAGLIUCA: Objection to form
7
and foundation.
8
A. You need to be very specific. I
9
have no idea what you are talking about.
10
That's completely rubbish.
11
Q. Did you or Jeffrey Epstein ask any
12
female to become pregnant and carry his baby
13
for either him or you?
14
MR. PAGLIUCA: Objection to the
15
form and foundation. Go ahead.
16
A. I can't testify to anything Jeffrey
17
did or didn't do when I am not present, but I
18
have never asked anybody to carry a baby for
19
me.
20
Q. Or anything along those lines?
21
MR. PAGLIUCA: Object to the form
22
and foundation.
23
Q. I want to make sure we are talking
24
about the same thing, not physically carry a
25
baby, I mean become pregnant with a baby?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 338 of 465
Page 338
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
Q. I want to make sure we are clear.
5
A. I don't know what you are asking.
6
Q. That's why I want to make sure we
7
are clear.
8
A. We are clear. I never asked
9
anybody to carry a baby for me.
10
Q. Do you know if Jeffrey ever asked
11
anybody to carry a baby for him?
12
A. I'm not going to characterize any
13
conversation Jeffrey had with somebody else.
14
Q. You are not aware of that, is that
15
your testimony?
16
A. I am testifying I never have and I
17
will not testify for anything for Jeffrey.
18
Q. Did you ever hear Jeffrey ask
19
anybody to carry a baby for him?
20
A. I don't recollect conversation
21
about Jeffrey and babies in any form.
22
Q. Did Jeffrey ever tell he wanted to
23
have a baby?
24
A. I don't recollect baby
25
conversations with Jeffrey.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 339 of 465
Page 339
1
G Maxwell - Confidential
2
Q. So he never told you he wanted to
3
have a baby?
4
A. I don't recollect any baby
5
conversations with him saying he wanted to
6
have a baby.
7
Q. Did you ever bring any females to
8
the
house that were not your friends'
9
children that were under the age of 18?
10
MR. PAGLIUCA: Objection to form
11
and foundation.
12
A. I have never, to my knowledge,
13
brought anybody under the age of 18 that's
14
not a friend of my family or my nieces or
15
nephews to the
household.
16
Q. Earlier today you testified, I
17
believe, that with respect to your town home
18
Jeffrey paid for some of that and then gave
19
you a loan, is that correct?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I said, actually I think it was a
23
loan, I believe it was a loan.
24
Q. The whole thing?
25
A. As best as I can recollect.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 340 of 465
Page 340
1
G Maxwell - Confidential
2
Q. Did you pay that loan back?
3
A. I don't have any outstanding loans
4
with him.
5
Q. So you paid it back?
6
A. I don't have any outstanding loans
7
with him.
8
Q. That's not an answer to my
9
question.
10
Did you pay back Jeffrey for the
11
loans?
12
A. I have paid back any loans I had
13
with him.
14
Q. You have or haven't?
15
A. Have.
16
Q. Were there any other gifts that
17
Jeffrey gave you during the time period of
18
say 1999 to the present that were in excess
19
of $50,000?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. What's the question again?
23
Q. Did Jeffrey give you any gifts in
24
excess of amounts of $50,000, I'm not talking
25
about a scarf here or something



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 341 of 465
Page 341
1
G Maxwell - Confidential
2
insignificant, from 1999 to the present?
3
A. I can't recollect any gifts.
4
Q. Did he ever buy you a car?
5
A. I really don't recall, I can't
6
recall, it's a long time ago.
7
Q. You can't recall if Jeffrey Epstein
8
ever bought you a car?
9
A. I believe he did buy me a car, I
10
don't recall how much it cost. I don't
11
recall any of the financial details of that.
12
Q. Do you still have that car?
13
A. I don't.
14
Q. How long ago did you get rid of
15
that car?
16
A. I don't recall all the cars. There
17
was a car back -- there was -- I don't
18
recall, I'm sorry.
19
Q. He supplied you with several cars?
20
MR. PAGLIUCA: Object to the form
21
and the mischaracterization of the
22
testimony.
23
A. I don't recall details of the cars.
24
Q. Did he supply with you more than
25
one car?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 342 of 465
Page 342
1
G Maxwell - Confidential
2
A. Over the course of time, I've
3
driven many cars.
4
Q. That Jeffrey provided to you?
5
A. They were cars that could be driven
6
and I just don't recall them.
7
Q. Were they in your name?
8
A. I don't recall.
9
Q. You don't recall if Jeffrey Epstein
10
ever put a car in your name?
11
A. We are talking a long time ago, I
12
really don't recall.
13
Q. When is the last time you had a car
14
from Jeffrey Epstein that you used?
15
A. 2000, 2001, 2002.
16
Q. Do you recall what kind of a car
17
that was?
18
A. I don't recall, I'm sorry.
19
Q. Did Jeffrey Epstein purchase
20
anything else for you besides the townhouse
21
and cars that would be over the amount of
22
$50,000?
23
A. I didn't say that he did, I said I
24
had a loan.
25
Q. Besides the loan, I'm sorry, you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 343 of 465
Page 343
1
G Maxwell - Confidential
2
are right, you did say you had a loan and you
3
said you paid that back, correct?
4
A. That's my testimony.
5
Q. Anything else in excess of $50,000
6
that he would have purchased for you?
7
A. We are talking 2002, 2001, I don't
8
recall any gifts really.
9
Q. When is the last time Jeffrey
10
Epstein gave you a gift in excess of $50,000?
11
MR. PAGLIUCA: Assumes facts not in
12
evidence. Form and foundation.
13
Q. You're saying you don't remember
14
from 2001 and 2002. I'm asking when is the
15
last time you remember Jeffrey Epstein
16
purchasing a gift for you?
17
A. I don't recall gifts in excess of
18
$50,000, I barely recall gifts, I barely
19
recall a lot of this -- I'm sorry, I don't
20
recall.
21
Q. Is Jeffrey Epstein paying for your
22
legal fees in this case?
23
A. No.
24
Q. Is he paying for anything related
25
to this case?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 344 of 465
Page 344
1
G Maxwell - Confidential
2
A. No.
3
Q. Are you aware of any grand theft
4
police report relating to Virginia Roberts?
5
A. I believe I've read a report in the
6
press on that.
7
Q. Did you provide the press with a
8
report on a grand theft by Virginia Roberts?
9
A. I don't know how the press got that
10
story.
11
Q. Do you know if Virginia Roberts
12
committed a grand theft?
13
A. I only know what I read in the
14
press.
15
Q. Did you ever state to the press
16
that Virginia Roberts committed a grand
17
theft?
18
A. I've never had any conversation
19
directly with press.
20
Q. Did any of your representatives
21
ever inform the press that Virginia Roberts
22
committed a grand theft?
23
MR. PAGLIUCA: Objection to the
24
form and foundation.
25
A. I have no way of knowing what my



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 345 of 465
Page 345
1
G Maxwell - Confidential
2
representatives said to press or didn't.
3
Q. Did they ever discuss with you the
4
fact that they were going to report that
5
Virginia Roberts participated in a grand
6
theft?
7
A. I don't know how, first of all, I
8
don't know how I know that. I believe I read
9
it in a press report so...
10
Q. I'm going to mark this as composite
11
exhibit, Maxwell 14 please?
12
(Maxwell Exhibit 14, email, marked
13
for identification.)
14
Q. I'm going to direct you to page GM
15
00109. At the top of that page you are going
16
to see an email address from Jeffrey Epstein
17
on Sunday June 12, 2011 to
18
19
A. Yes.
20
Q. The re line says, This is the
21
actual version they wanted me to send which I
22
changed but this is back from my U.K.
23
lawyers.
24
Do you see that?
25
A. Yes.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 346 of 465
Page 346
1
G Maxwell - Confidential
2
Q. If you go down further, you're
3
going to see halfway through the page, you
4
will see your email address the
5
and you will see a statement that says, Thank
6
you. I have it now. I'm working on the
7
letter a little. I will send final version
8
tomorrow and whatever is in it will be
9
factually accurate.
10
Beneath that you will see
11
who I believe you identified earlier
12
as one of your attorneys?
13
A. Uh-huh.
14
Q. And you will see a letter, starting
15
the text of a letter starting, I want you to
16
turn to the second page which is GM 00110.
17
About halfway through the page, it says you
18
will also presumably draw attention to the
19
fact that prior to filing her suit against
20
Mr. Epstein, Ms. Roberts fled the U.S. to
21
avoid being arrested for grand theft. Police
22
report available.
23
What grand theft were you referring
24
to there that Virginia Roberts committed?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 347 of 465
Page 347
1
G Maxwell - Confidential
2
form and foundation.
3
A. I don't know. However, I believe
4
she stole money from somewhere where she
5
worked.
6
Q. How do you know that was grand
7
theft?
8
A. I don't know how I know that.
9
Q. So you authorized a statement that
10
characterized that as grand theft without
11
knowing whether it was grand theft?
12
A. What month, what is the date of
13
this?
14
Q. The date of this is June 12, 2011?
15
A. So I'm afraid such a long time ago,
16
I'm not sure how, I really couldn't testify
17
as to how that language ended up in here.
18
Q. Do you have the police report? It
19
says police report available. Do you have
20
that document?
21
A. I don't have that document.
22
Q. Who does?
23
A. I have no idea.
24
Q. Would your lawyer
25
have that document?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 348 of 465
Page 348
1
G Maxwell - Confidential
2
A. I don't know who has this document.
3
Q. What's your basis in that statement
4
for saying Ms. Roberts fled the U.S.?
5
A. Again, you are asking me for a
6
statement that I made in 2011 and I can't say
7
what in 2011 exactly the basis of that
8
statement was.
9
Q. So you don't know whether or not
10
that statement is true?
11
A. This is in 2011 and it never went
12
out, so I'm not sure exactly.
13
Q. But you said in your email that you
14
were working to make it factually accurate,
15
is that correct?
16
A. That's what it says.
17
Q. I'm going to mark as Maxwell 15 a
18
document dated February 24, 2015?
19
(Maxwell Exhibit 15, email, marked
20
for identification.)
21
Q. This is an email from
who
22
you've identified as your
on
23
February 24, 2015 to
which I understand
24
to be your email address and
.
25
The subject line says, VR cried rape. Prior



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 349 of 465
Page 349
1
G Maxwell - Confidential
2
case dismissed as prosecutors found her not
3
credible. The message says, Ghislaine, some
4
helpful leakage, dot dot dot. What is it you
5
were leaking to the press?
6
MR. PAGLIUCA: Objection, there is
7
no foundation that she leaked anything
8
and you know that.
9
Q. What was it that you were leaking
10
to the press in that statement?
11
A. Again, I don't think that's
12
referring to that, that's just referring to
13
the press getting hold of whatever story it
14
is.
15
Q. What was
leaking to the
16
press?
17
MR. PAGLIUCA: Objection to form
18
and foundation.
19
A. It doesn't say
was leaking
20
anything. It doesn't say that.
21
Q. The statement says, helpful
22
leakage, is that correct?
23
A. It says helpful leakage. That
24
doesn't mean he leaked anything.
25
Q. Did you leak to the press



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 350 of 465
Page 350
1
G Maxwell - Confidential
2
information to the press information about
3
the subject line, VR cried rape, prior case
4
dismissed as prosecutors found her not
5
credible?
6
A. I don't no idea what
is
7
referring to. I think he is referring to the
8
press held the story. I couldn't testify to
9
that.
10
Q. Did you leak to the press
11
information regarding the statement, VR cried
12
rape prior case dismissed as prosecutors
13
found her not credible, either through you or
14
through
?
15
A. I think this is coming from the
16
daily mail.
17
Q. That is not my question, I'm asking
18
whether you or
leaked that?
19
A. I have no knowledge, I have no
20
idea, I'm sorry. I can't -- I have no
21
recollection. I have no idea what she is
22
talking about.
23
Q. I'm going to mark this as 16?
24
(Maxwell Exhibit 16 email marked
25
for identification.)



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 351 of 465
Page 351
1
G Maxwell - Confidential
2
Q. This is an email addressed at the
3
top from Jeffrey Epstein on Monday, January
4
12, 2015 to
which I understand to be
5
your email address. The email reads, You can
6
issue a reward to any of Virginia's friends,
7
aquaints, family, that come forward to help
8
prove her allegations are false. The
9
strongest is the
dinner and the new
10
version of the Virgin Islands that
11
practiced in an underage orgy.
12
Did you offer any rewards to
13
Virginia's family or friends to contradict
14
Virginia's story?
15
A. Absolutely not.
16
Q. Did Jeffrey Epstein offer any
17
rewards to any of Virginia's, as he suggests
18
here, friends, family or acquaintances to
19
contradict Virginia's story?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I have no idea what he did.
23
Q. Did he tell he was going to offer
24
rewards to Virginia's acquaintances, friends
25
and family to prove her allegations were



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 352 of 465
Page 352
1
G Maxwell - Confidential
2
false?
3
A. He did not.
4
Q. Do you know whether Jeffrey Epstein
5
paid
to give testimony about
6
Virginia Roberts?
7
A. I don't know who
is.
8
Q. So you don't know whether Jeffrey
9
Epstein paid her?
10
A. I don't know who
is.
11
Q. Have you ever contacted any of
12
Virginia's friends, acquaintances or family
13
regarding this case?
14
A. I don't know who Virginia's friends
15
or family are and I have not contacted
16
anybody related to her in any way, shape or
17
form.
18
Q. I will turn you, I believe it's the
19
thicker document which is Maxwell, I believe
20
it was 14, right there, the compilation
21
document to GM, at the bottom, GM 00071. You
22
actually may want to turn to the prior page
23
70 so you can see the email chain. At the
24
top of the page --
25
MR. PAGLIUCA: I don't have a 00071



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 353 of 465
Page 353
1
G Maxwell - Confidential
2
on mine.
3
MS. McCAWLEY: It's the second page
4
in that document.
5
MR. PAGLIUCA: Okay.
6
Q. It's dated Friday March 11, 2011
7
from Maxwell to Jeffrey with the title, Daily
8
Mail and there is a forward from
to
9
you and a number of other individuals, that's
10
on the cover page and as you scroll to the
11
second page, you are going to see that part
12
of the chain that I'm asking about and that
13
is the chain at the bottom which is dated
14
3/10/2011 from
and it says we
15
think -- we should think about the letter to
16
the editor. School can be university. Age
17
of consent in Florida is complex. See below,
18
if you are 16 years old, a sexual
19
relationship with someone between 18 and 24
20
is legal in Florida. Two persons between 16
21
and 24, Florida statute 794.05. A person 24
22
years or of age or older who engages in
23
sexual activity with a person 16 or 17 years
24
of age commits a felony in the second degree.
25
So as soon as you turn 16 you are able to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 354 of 465
Page 354
1
G Maxwell - Confidential
2
have sexual relations and you can have sexual
3
relations with a minor under the age of 18
4
until your 24th birthday.
5
Why were you concerned with the age
6
of consent in Florida?
7
MR. PAGLIUCA: Objection to the
8
form and foundation of the question.
9
A. I wasn't concerned. I think this
10
was somebody sending me the statute for
11
informational purposes.
12
Q. Who is
?
13
A. He is the person who,
14
boss I believe, I don't know what the
15
relationship is.
16
Q. I didn't hear you?
17
A. I
I'm not
18
sure exactly.
19
Q. Why would he be sending you
20
information addressing concerns about the age
21
of consent in Florida?
22
MR. PAGLIUCA: Objection to the
23
form and foundation.
24
A. I think he was just trying to be --
25
telling me details that would happen,



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 355 of 465
Page 355
1
G Maxwell - Confidential
2
Virginia in '11 was claiming she was 15 and
3
we thought she was 17. I didn't know what
4
the statutes were in Florida and I think he
5
was just trying to be helpful so I would
6
know.
7
Q. Did you have a concern that you had
8
violated this statute in Florida?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. No.
12
Q. Did you have a concern that Jeffrey
13
Epstein had violated this statute in Florida?
14
A. I'm not concerned what happened
15
with Jeffrey. I'm only concerned what
16
happens with me.
17
Q. Why did you communicate with
18
about the sexual consent age in
19
Florida?
20
MR. PAGLIUCA: Objection to the
21
form and foundation. It misstates her
22
testimony.
23
A. I wasn't concerned. I think he was
24
being helpful and stating what the statute
25
was.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 356 of 465
Page 356
1
G Maxwell - Confidential
2
Q. I'm going to turn you now in that
3
same stack the Bates number GM 00088. At the
4
top of the email you are going to see Jeffrey
5
Epstein, dated June 8, 2011, to you and it's
6
got a re line, Vanity Fair. If you go down
7
the chain you will see where it says under
8
your email, Do you have a problem with
9
anything I said.
10
Were you communicating with Jeffrey
11
to confirm what statements you could put in
12
any press releases you were given?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. Any interest I have is in accuracy.
16
Q. Were you confirming with Jeffrey
17
Epstein what information you could put in
18
press releases?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. Again, I'm only looking for
22
accuracy.
23
Q. Why would you ask him if he had a
24
problem with anything you were saying?
25
A. If there is anything I



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 357 of 465
Page 357
1
G Maxwell - Confidential
2
characterized that was not correct.
3
Q. That's not what you said. You
4
said, do you have a problem with anything I
5
said.
6
MR. PAGLIUCA: Objection to the
7
form and foundation. There is no
8
question pending.
9
MS. McCAWLEY: There is.
10
MR. PAGLIUCA: That's not a
11
question, it's a statement.
12
MS. McCAWLEY: Don't interrupt me.
13
Q. Di you say, do you have a problem
14
with anything I said?
15
A. That was asking in my parlance that
16
I wanted him to check it for accuracy.
17
Q. Did he tell you there was anything
18
inaccurate about the statement?
19
A. Again, I have to read the whole
20
thing to figure that out.
21
Q. Were you coordinating with Jeffrey
22
Epstein during this time period in 2011
23
regarding statements that you were issuing to
24
the press?
25
MR. PAGLIUCA: Did you withdraw the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 358 of 465
Page 358
1
G Maxwell - Confidential
2
last question.
3
MS. McCAWLEY: I'm not withdrawing
4
anything. I'm asking a question.
5
MR. PAGLIUCA: There was a question
6
pending. You didn't let the witness
7
answer the question, then you moved on
8
to another question so I'm asking for
9
clarification for the record now which
10
question are we answering.
11
MS. McCAWLEY: There is an answer.
12
The question was did he tell you
13
anything, there was anything in the
14
statement inaccurate about the statement
15
and she said again, I read the whole
16
thing --
17
THE WITNESS: I would have to.
18
MS. McCAWLELY: -- I would have to
19
read the whole thing to figure that out.
20
MR. PAGLIUCA: Then she started
21
reading it and you asked another
22
question.
23
MS. McCAWLEY: That's the question.
24
MR. PAGLIUCA: I'm wondering if its
25
still pending.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 359 of 465
Page 359
1
G Maxwell - Confidential
2
MS. McCAWLEY: It was answered.
3
Q. Were you coordinating with Jeffrey
4
Epstein during the time period in 2011
5
regarding the statements you were issuing to
6
the press?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I only wanted to be accurate in any
10
factual statements that I made.
11
Q. You knew at that time that Jeffrey
12
Epstein had been convicted for sexual abuse
13
of a minor, is that correct?
14
MR. PAGLIUCA: Objection to form
15
and foundation.
16
A. He was sentenced I believe for
17
underage -- soliciting an underaged
18
prostitute.
19
Q. You knew that he was a registered
20
sex offender?
21
A. Yes.
22
Q. You were coordinating with him the
23
statement that you were going to be making to
24
the press to confirm whether they were
25
accurate in your words?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 360 of 465
Page 360
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I was not coordinating with
5
Jeffrey. He had details that I did not have.
6
I was not party to his case. I needed to
7
have information in order to be able to
8
respond so I was not coordinating with him.
9
I was merely asking for details that I could
10
have.
11
Q. Did Jeffrey write any of your press
12
statements for you?
13
A. No.
14
Q. He didn't draft any of them?
15
A. I have a lawyer who was working on
16
this and that was -- I asked, I believe as I
17
recollect asked him for information to make
18
sure I was being accurate in the
19
representations for whatever I was
20
discussing.
21
Q. Did Jeffrey provide you with any
22
drafts of statements to provide to the press?
23
A. I only recall drafts from my
24
lawyer.
25
Q. I will mark this as Maxwell 17.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 361 of 465
Page 361
1
G Maxwell - Confidential
2
(Maxwell Exhibit 17, email, marked
3
for identification.)
4
Q. This is an email from you on
5
January 10, 2015 to
6
The statement you had before you
7
earlier, that, if you can pull that in front
8
of you, the one page press release that you
9
gave. You might know from memory.
10
Was the press release that you
11
issued with the statement about Virginia
12
issued in or around January 2, 2015?
13
A. As best as I can recollect.
14
Q. I want to turn your attention to
15
the document I just handed you which is Bates
16
No. 001044, from you to
17
It says in the first sentence, I'm
18
out of my depth to understand defamation,
19
other legal hazards and I don't want to end
20
up in a lawsuit aimed at me from anyone, if I
21
can help it. Apparently, even saying
22
Virginia is a liar has hazards.
23
You knew at the time you called
24
Virginia a liar in early January of 2015 that
25
that was something that would result in a



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 362 of 465
Page 362
1
G Maxwell - Confidential
2
lawsuit, is that correct?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. I have legal advice that I took.
6
Q. But you knew in early January by
7
making a statement calling Virginia a liar
8
that you were subjecting yourself to a legal
9
dispute with her?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. I took legal advice as to what
13
should be said and not be said and the legal
14
advice that came from the United Kingdom
15
was --
16
MR. PAGLIUCA: You are not allowed
17
to talk about any legal advice that you
18
got from anybody that's a lawyer.
19
A. Sorry.
20
Q. So is it correct without telling me
21
what you talked to your lawyers about that
22
you knew because this is dated January 10
23
that when you made this statement in early
24
January, January 2 of 2015 you knew that
25
calling Virginia a liar would subject you to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 363 of 465
Page 363
1
G Maxwell - Confidential
2
a legal action, isn't that correct?
3
MR. PAGLIUCA: Objection to the
4
form and foundation. As to what you
5
knew -- whatever she knows would be
6
privileged.
7
MS. McCAWLEY: I'm asking if she
8
knows. I'm not asking her to tell me
9
about her privileged communications.
10
A. All I can say is I asked a question
11
and received legal advice.
12
(Maxwell Exhibit 18, email, marked
13
for identification.)
14
Q. This is an email dated January 15,
15
2015 from Jeffrey Epstein to you?
16
A. Uh-huh.
17
Q. It states in the first line, do you
18
want
to come out and say she was the
19
girlfriend during the time?
20
MR. PAGLIUCA: Objection to the
21
form and foundation of the question and
22
actually the word is
, there
23
is no vowel in there.
24
MS. McCAWLEY: I was just trying to
25
pronounce it.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 364 of 465
Page 364
1
G Maxwell - Confidential
2
Q. This email reads do you want
3
without a vowel, to come out and say
4
she was the girlfriend during the time.
5
Who was Jeffrey Epstein referring
6
to?
7
A. I believe he was referring to
8
.
9
Q. Why was he asking you if you wanted
10
to come out and say she was the
11
girlfriend?
12
MR. PAGLIUCA: Objection to the
13
form and foundation.
14
A. The way the press and you were
15
characterizing me is I was with Jeffrey
16
throughout this entire period of time and I
17
was not.
18
Q. Was
with Jeffrey during this
19
period of time?
20
A. I believe she was.
21
Q. Did Jeffrey come out and tell the
22
press it was
and not you that was with
23
him as he is proposing here?
24
A. I don't believe he did.
25
Q. Did you want him to do that?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 365 of 465
Page 365
1
G Maxwell - Confidential
2
A. No, I didn't ask him to do
3
anything. No.
4
Q. So do you know in January of 2015,
5
was
his girlfriend?
6
A. 2015, I have no idea who was his
7
girlfriend in 2015.
8
Q. I'm sorry, you are correct.
9
In the period of 1999 to 2002, was
10
his girlfriend?
11
A. They spent a lot of time together.
12
Q. Did you talk to
about going
13
to the press and saying that she was the
14
girlfriend and not you?
15
A. I have never spoken to
16
Q. Was
offered any money to
17
make a statement that she was the girlfriend?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I have no idea. I have never
21
spoken to
and I don't know anything --
22
I have no idea.
23
(Maxwell Exhibit 19, email, marked
24
for identification.)
25
Q. That's an email from Jeffrey to



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 366 of 465
Page 366
1
G Maxwell - Confidential
2
Maxwell dated January 25, 2015.
3
A. Uh-huh.
4
Q. I will direct your attention to the
5
bottom email which is from you on Saturday
6
January 24, 2015. It says, I would
7
appreciate it if
would come out and
8
say she was your girlfriend. I think she was
9
from the end of '99 to 2002.
10
Does that refresh your recollection
11
that you asked Jeffrey to have
come
12
out and say she was his girlfriend?
13
A. I'm sure I would loved anybody to
14
come out and say they were with Jeffrey
15
rather than me.
16
Q. Was that an accurate statement you
17
were asking to be made to the press?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. When is this?
21
Q. 2015. The statement is whether she
22
was the girlfriend from '99 to 2002. As the
23
email reads.
24
A. What is your question?
25
Q. My question is, was that an



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 367 of 465
Page 367
1
G Maxwell - Confidential
2
accurate statement you were going to be
3
giving to the press?
4
A. I didn't make the statement and
5
never came out, so it's completely
6
moot.
7
Q. My question is, was it an accurate
8
statement that
was the girlfriend from
9
'99 to 2002 or were you just making that up
10
for purposes of deflecting press from you?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. As I said they spent a lot of time
14
together and...
15
Q. Were you also his girlfriend from
16
'99 to 2002?
17
A. I don't if I would have ever
18
characterized myself as his girlfriend, but
19
at that time, was with him as much if
20
not more than I was.
21
Q. I will mark this as Maxwell 20?
22
(Maxwell Exhibit 20, email, marked
23
for identification.)
24
Q. This is an email at the top, it's
25
Bates labled 001060. At the top is a chain



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 368 of 465
Page 368
1
G Maxwell - Confidential
2
from Jeffrey to you on January 11, 2015 and
3
if you look below, I'm going to start at the
4
bottom of that chain which is January 11 at
5
9:15 from Jeffrey and he wrote,
do you
6
have an article coming out in Monday's paper.
7
If so, could you please forward us a copy.
8
Do you know what
Jeffrey was
9
referring to there?
10
A. I don't know.
11
Q. If you look up in the email chain
12
do you see an email address from
13
responding to that letter?
14
A. I do.
15
Q. So that would be
16
that Jeffrey was emailing at that time
17
according to this chain, correct?
18
A. It certainly looks like it.
19
Q. The email from
to Jeffrey is,
20
Nothing on Monday. I'm working on several
21
possible articles about unfairness in the
22
legal process that allows false charges to be
23
inserted into legal documents with no
24
opportunity to respond.
25
And do you see above that Jeffrey's



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 369 of 465
Page 369
1
G Maxwell - Confidential
2
email to you says, quote, Careful.
3
A. Is that to me or to
4
Q. Jeffrey to
at the top. Why
5
was Jeffrey telling you to be careful?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I have no idea.
9
Q. What was he concerned about with
10
suggestion in the email
11
below?
12
MR. PAGLIUCA: Objection to form
13
and foundation.
14
A. I can't possibly know.
15
Q. Did you discuss with him why he
16
told you to be careful?
17
A. I had limited contact with him. I
18
don't recall where this goes in the chain,
19
why he was telling me to be careful, I have
20
no idea.
21
Q. Did you respond to this email?
22
A. If you don't have it, I didn't
23
respond.
24
Q. Did you ever delete emails during
25
the period of January of 2015?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 370 of 465
Page 370
1
G Maxwell - Confidential
2
A. I have every email that you asked
3
for in discovery, that I have I gave you.
4
Q. That's not my question.
5
Did you ever delete emails in
6
January of 2015?
7
A. I have not deleted anything that
8
you have asked me for in discovery. I have
9
given you everything that I have.
10
Q. That is not my question, my
11
question is, did you ever delete emails in
12
January of 2015?
13
A. In the normal course of my work,
14
there are emails from spam that I delete.
15
That is the type of email I've deleted.
16
Anything that is material to what you want, I
17
have not deleted.
18
Q. How do you know that?
19
A. Well, anybody that's to do with
20
Jeffrey or
or women or anything of which
21
I know you were interested in, of which I
22
have anything I would not have done because I
23
don't want to subject myself to...
24
Q. Have you had your computer
25
forensically copied for purposes of this



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 371 of 465
Page 371
1
G Maxwell - Confidential
2
litigation?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. Has someone made a copy of your
6
computer for purposes of this litigation.
7
A. No.
8
Q. Are you a citizen of the United
9
States?
10
A. I am.
11
Q. Are you also a citizen of England?
12
A. I am.
13
Q. Are you a citizen of any other
14
land?
15
A. TerraMar.
16
Q. That's the name of your charity
17
project that deals with oceans, is that
18
correct?
19
A. Yeah. I'm French as well.
20
Q. Has Jeffrey Epstein funded TerraMar
21
for you?
22
A. He did give some money to TerraMar,
23
yes.
24
Q. How much?
25
A. I believe it was $50,000.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 372 of 465
Page 372
1
G Maxwell - Confidential
2
Q. Earlier today, you said you were in
3
the process of resolving the sale of your
4
town home. Where do you intend to live once
5
your town home is sold?
6
A. That's a good question. I don't
7
have an answer for you yet.
8
Q. You don't have a present plan. Do
9
you intend to live in the United States?
10
A. I don't have a present plan.
11
Q. Are you living outside of your town
12
home right now or are you still there?
13
A. I'm just couch surfing.
14
Q. Has Jeffrey Epstein ever purchased
15
a company for you or put a company in your
16
name?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I have no recollection.
20
Q. Is there a Ghislaine Maxwell
21
corporation, for example?
22
A. No, not that I am aware of that has
23
anything to do with me. There may be with
24
one that someone else owns or started but not
25
one that is related to me.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 373 of 465
Page 373
1
G Maxwell - Confidential
2
MS. McCAWLEY: I'm going to take a
3
short break and make sure to keep it
4
short because I know you wanted to -- I
5
just want to wrap up what we have left.
6
THE VIDEOGRAPHER: It's now 5:49 we
7
are off the record.
8
(Recess.)
9
THE VIDEOGRAPHER: It's now 6:00
10
p.m. and we are back on the record.
11
Q. Ms. Maxwell, do you recall being
12
subpoenaed for a deposition back in 2009?
13
A. I do.
14
Q. Why did you avoid giving your
15
deposition in that case when you were
16
subpoenaed and had the opportunity to tell
17
your side of the story?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. That's not what happened.
21
Q. What happened?
22
A. As I best recall, I was subpoenaed
23
and a date was set for the subpoena and
24
everything was set and I believe it was with
25
Brad Edwards, correct me if I'm wrong, and



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 374 of 465
Page 374
1
G Maxwell - Confidential
2
Brad Edwards failed to show up for the
3
subpoena.
4
Q. So your testimony is Brad Edwards
5
did not show up for the deposition that had
6
been set?
7
A. Correct.
8
Q. Did you give any statement that
9
your mother was ill and, therefore, you
10
couldn't take your deposition and had to
11
leave the country indefinitely?
12
A. That's an entirely separate
13
situation. Brad Edwards was involved in the
14
, I
15
believe, you know, is when fake suits were
16
created in Jeffrey's case and
and Brad Edwards worked
18
for that firm.
19
Q. And Mr. Edwards worked for that
20
firm?
21
A. So when the subpoena came, Brad
22
Edwards was involved with
in the
23
case so when I was called for subpoena, then
24
and I had a subpoena, date and time set, Brad
25
Edwards went AWAL, meaning he failed to




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 375 of 465
Page 375
1
G Maxwell - Confidential
2
respond to calls and failed to get in touch
3
with my attorneys, even though a date and
4
time was set for the subpoena and so that's
5
what happened to that subpoena. It just
6
didn't happen.
7
Q. We may be talking about two
8
different cases so I will ask the question
9
again.
10
Was there ever a time where you
11
were subpoenaed to sit for a deposition that
12
you could not make it because you said that
13
your mother was ill?
14
A. So that is the same subpoena that
15
Brad Edwards failed to turn up for and then I
16
think five or six months passed between -- a
17
period of time, I can't characterize it
18
exactly, a period of time passed where then
19
he resurfaced and asked for a new subpoena to
20
be -- a new time to be set and because he had
21
contacted the press and done all sorts of
22
things that you guys are familiar with, I
23
believe, it was my lawyer suggested that I
24
should have some sort of protective order and
25
I believe between the time for when Brad



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 376 of 465
Page 376
1
G Maxwell - Confidential
2
Edwards resurfaced after the
for
4
creating fake cases in Jeffrey's and other
5
people's cases, in between the time when
6
there were -- trying to figure out the
7
protective situation for me, my mother was
8
sick, she is 89, she was 89 at that time so I
9
-- they -- we can all -- we all have parents,
10
so anyone, I don't know how old your parents
11
are but any parent or godparent, any
12
individual who is in the late 80s 90s, we can
13
understand has health issues so my mother's
14
health was deteriorating very rapidly at that
15
time and we had issues at home with who she
16
would talk to and how to manage her, her
17
healthcare situation and so I went home.
18
They were still arguing about the protective
19
order --
20
Q. Is it your testimony that there was
21
not a date set for your deposition at the
22
time you left to go see your mother?
23
A. I don't believe so.
24
Q. Are you friends with the
25
A. I am.




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 377 of 465
Page 377
1
G Maxwell - Confidential
2
Q. Did you attend a wedding of
3
a few weeks after the date was set,
4
let's say a few weeks after you left to go
5
see your mother who was ill?
6
A. I don't recall exactly when I left
7
but it was before, a few weeks before -- I
8
don't remember the exact timing of that, so
9
I'm sorry, can you repeat the question?
10
Q. Did you come back to the United
11
States to attend
wedding?
12
A. I attended
13
wedding but I don't know if I came back
14
specifically for that or not.
15
Q. When we were looking at the flight
16
logs earlier, there was a flight where you
17
ended up in
, I believe it was
18
in
do you know how you got clearance
19
to land at that
?
20
A. I need to have a look at whatever
21
document.
22
Q. It's one of the flight logs, it was
23
on the flight with
when we were
24
talking about you landed at
I
25
know you are a pilot, do you know what you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 378 of 465
Page 378
1
G Maxwell - Confidential
2
had to do to get clearance to land at that
3
naval base.
4
MR. PAGLIUCA: If you need to look
5
at something to answer the question, you
6
can. If you can't answer the question
7
without looking at something just
8
indicate such.
9
A. Regardless, I wouldn't have any
10
knowledge of that.
11
Q. Was
traveling with you
12
on the flights you were on with
13
A. I would have to look at a document.
14
I wouldn't know if she was on all of them or
15
not. I don't know.
16
Q. Do you recall her being on any of
17
them?
18
A. To the best of my recollection, I
19
think she was. I don't recollect exactly
20
what flight she was on or not.
21
Q.
was one of the
22
co-conspirators, physically, in the
23
nonconstitution agreement, is that correct?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 379 of 465
Page 379
1
G Maxwell - Confidential
2
A. I have never seen the document but
3
my understanding, I believe, is that she was.
4
Q. Did you ever stay the night ever at
5
house
have you ever
6
stayed the night there?
7
A. In his home
8
Q. Yes.
9
A. I don't believe I did.
10
Q. Are you aware of anybody providing
11
Jeffrey with two 12 year old girls as a
12
birthday present?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. No.
16
Q. Are you aware of anybody ever
17
providing Jeffrey with French girls under the
18
age of 18 as a birthday present?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. No.
22
Q. Do you know whether
23
provided girls under the age of 18 to Jeffrey
24
for the purposes of sex?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 380 of 465
Page 380
1
G Maxwell - Confidential
2
form and foundation.
3
A. I am un -- the answer is no, I
4
don't know anything about that.
5
Q. Did you ever witness
6
bringing girls under the age of 18 to
7
any of Jeffrey residences?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I don't recollect
coming
11
to the house with girls, period.
12
Q. Do you, when I say house, I'm
13
including the U.S. Virgin Island home.
14
Do you recollect
15
bringing foreign girls under the age of 18 to
16
the U.S. Virgin Island house?
17
A. I don't recollect anything like
18
that.
19
Q. Do you know how Jeffrey Epstein
20
made his money?
21
A. No.
22
Q. Was
one
23
of his clients?
24
A. I have no idea.
25
Q. What do you know about the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 381 of 465
Page 381
1
G Maxwell - Confidential
2
relationship between Jeffrey Epstein and
3
4
A. Are you talking today?
5
Q. Yes, today.
6
A. I have no idea.
7
Q. Do they have a business
8
relationship?
9
A. I have no idea.
10
Q. Did they have a business
11
relationship during the time that you were
12
working for Jeffrey Epstein?
13
A. I believe in the '90s when I was
14
there they had a business relationship.
15
Q. Did they have any other kind of
16
relationship?
17
MR. PAGLIUCA: Objection to form
18
and foundation.
19
A. The only relationship I am aware of
20
is the business relationship.
21
Q. Do you know why
sold the
22
New York house or gave the New York house to
23
Jeffrey, if you know?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 382 of 465
Page 382
1
G Maxwell - Confidential
2
A. I know nothing about that
3
transaction.
4
Q. Can you list for me all the girls
5
that you have met and brought to Jeffrey
6
Epstein's house that were under the age of
7
18?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I could only recall my family
11
members that were there and I could not make
12
a list of anyone else because that list -- it
13
never happened that I can think of.
14
Q. I'm talking about the time you were
15
working for Jeffrey Epstein, can you list all
16
girls that you found for Jeffrey Epstein that
17
were under the age of 18 to come work for him
18
in any capacity?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I didn't find the girls.
22
Q. You choose the word.
23
MR. PAGLIUCA: If you have a
24
question ask it, you don't choose the
25
word.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 383 of 465
Page 383
1
G Maxwell - Confidential
2
Q. List all of the girls you met and
3
brought to Jeffrey Epstein's home for the
4
purposes of employment that were under the
5
age of 18?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I've already characterized my job
9
was to find people, adults, professional
10
people to do the jobs I listed before; pool
11
person, secretary, house person, chef, pilot,
12
architect.
13
Q. I'm asking about individuals under
14
the age of 18, not adult persons, people
15
under the age of 18.
16
A. I looked for people or tried to
17
find people to fill professional jobs in
18
professional situations.
19
Q. So Virginia Roberts was under the
20
age of 18, correct?
21
A. I think we've established that
22
Virginia was 17.
23
Q. Is she the -- sorry, go ahead.
24
Is she the only individual that you
25
met for purposes of hiring someone for



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 384 of 465
Page 384
1
G Maxwell - Confidential
2
Jeffrey that was under the age of 18?
3
MR. PAGLIUCA: Objection to form
4
and foundation. Mischaracterizes her
5
testimony.
6
A. I didn't hire people.
7
Q. I said met.
8
A. I interviewed people for jobs for
9
professional things and I am not aware of
10
anyone aside from now Virginia who clearly
11
was a masseuse aged 17 but that's, at least
12
that's how far we know that I can think of
13
that fulfilled any professional capacity for
14
Jeffrey.
15
Q. List all the people under the age
16
of 18 that you interacted with at any of
17
Jeffrey's properties?
18
A. I'm not aware of anybody that I
19
interacted with, other than obviously
20
Virginia who was 17 at this point?
21
(Maxwell Exhibit 21, email, marked
22
for identification.)
23
Q. I'm showing you what's been marked
24
as Maxwell 21, it's an email dated January
25
21, 2015 from Jeffrey to you. Is that, you



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 385 of 465
Page 385
1
G Maxwell - Confidential
2
can take a moment to take a look at it, is
3
that a statement that Jeffrey Epstein wrote
4
for you to be issued to the press?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. The question was?
8
Q. Is this a statement that Jeffrey
9
Epstein wrote for you to be issued to the
10
press?
11
MR. PAGLIUCA: Same objection.
12
A. Is there any other emails that you
13
have that surround this that would allow me
14
to know what -- does this have a context?
15
Q. These were produced by your counsel
16
so the to extent there are emails that
17
surround this, this is what we were given.
18
A. Okay. I don't know whether he
19
wrote this -- obviously he wrote this and
20
sent this to me. I don't know if this is
21
post a phone call we had, I can't recollect
22
exactly.
23
Q. Do you know if this was issued to
24
the press, this statement?
25
A. The only press statement that was



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 386 of 465
Page 386
1
G Maxwell - Confidential
2
issued is the one that you have.
3
Q. When the paragraph refers to you
4
being in a very long term committed
5
relationship with another man, who was that
6
other man?
7
MR. PAGLIUCA: You don't have to
8
answer the question.
9
MS. McCAWLEY: I'm asking the
10
identity of a witness in a statement she
11
is giving.
12
MR. PAGLIUCA: She didn't give the
13
statement.
14
MS. McCAWLEY: Jeffrey is writing
15
to her, I'm asking who is he is
16
referencing to a long term relationship.
17
You are going to refuse to let her
18
answer that question.
19
MR. PAGLIUCA: Yes.
20
MS. McCAWLEY: I would like to
21
state for the record he is refusing to
22
allow her to identify a potential
23
witness in this litigation. So we will
24
be back to get the answer to that
25
question.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 387 of 465
Page 387
1
G Maxwell - Confidential
2
Q. Do you recall when you were
3
traveling with Virginia Roberts that you
4
would be responsible for holding her
5
passport?
6
MR. PAGLIUCA: Objection to the
7
form and foundation.
8
A. I already testified I don't recall
9
traveling with Virginia.
10
Q. Do you recall whether Jeffrey
11
Epstein when he was traveling with a minor,
12
someone under the age of 18, someone would
13
hold their passport?
14
MR. PAGLIUCA: Object to the form.
15
A. I couldn't testify to what Jeffrey
16
did or didn't do.
17
Q. You never observed him gathering a
18
minor's passport and holding it during one of
19
the trips you were on?
20
A. I don't have a recollection of
21
that.
22
Q. Are you familiar with a company
23
called Hyperion Air Inc.?
24
A. I am.
25
Q. Is that a company you are



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 388 of 465
Page 388
1
G Maxwell - Confidential
2
affiliated with?
3
A. No.
4
Q. Is that a company that Jeffrey
5
owns?
6
A. I knew it back in 2001, back when I
7
was working. I have no idea what that is
8
today.
9
Q. What about JEGE, are you familiar
10
with that company, JEGE Inc.?
11
A. I don't recall it.
12
Q. You don't recall?
13
A. It vaguely rings a bell. I don't
14
remember what it relates to.
15
Q. What about J Epstein Virgin Islands
16
Foundation, Inc.
17
Are you familiar with that company?
18
A. No.
19
Q. How did J Epstein & Company, Inc.?
20
A. Again, I don't recall his business
21
names and affiliations.
22
Q. How about NES LLC, are you familiar
23
with that name?
24
A. Again, I think that was one of his
25
businesses, but I don't recall.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 389 of 465
Page 389
1
G Maxwell - Confidential
2
Q. Do you know what that business did?
3
A. I don't.
4
Q. How about New York Strategy Group
5
Inc.?
6
A. I don't know.
7
Q. What about Ghislaine Maxwell
8
Company, are you familiar with that company?
9
A. I never heard of that.
10
Q. Is that a company you are on record
11
as being either a board member of or having a
12
position of authority in?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I've never heard of the business.
16
Q. What negative, unflattering,
17
private or potentially embarrassing
18
information does Jeffrey Epstein know about
19
you?
20
MR. PAGLIUCA: Objection to the
21
form and foundation.
22
A. I imagine none.
23
Q. Does he know, does he have any
24
knowledge of any illegal activity that you've
25
conducted?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 390 of 465
Page 390
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Object to the form
3
and foundation.
4
A. If you want to ask Jeffrey
5
questions about me, you would have to ask
6
him.
7
Q. Have you ever been involved in any
8
illegal activity in your lifetime?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I can't think of anything I have
12
done that is illegal.
13
Q. Have you ever been arrested?
14
A. I have a DUI in the U.K. a long
15
time ago.
16
Q. Is that the only arrest you have on
17
your record?
18
A. Yes.
19
Q. I will mark as Maxwell 22 this
20
email?
21
(Maxwell Exhibit 22, email, marked
22
for identification.)
23
Q. This is dated January 21, 2015.
24
It's from Jeffrey Epstein to you, forwarding
25
the Guardian and I would like you to look at



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 391 of 465
Page 391
1
G Maxwell - Confidential
2
the chain of emails so you understand the --
3
have an appreciation for who is on this.
4
It's a three-page document. The bottom of
5
the email appears to be a message from, there
6
is a -- at the very bottom there is the
7
signature block for
,
and above that
9
there is a message from a

10
11
Do you see that?
12
A. Uh-huh.
13
Q. Do you know who
is?
14
A. I do not.
15
Q. Above that there is a message from
16
and you and it
17
says, so this isn't getting better, latest
18
from our chums at the Guardian and above that
19
you will see on January 21 an email from you
20
where you wrote, See below.
21
And right above that chain you will
22
see Jeffrey Epstein to you on January 21 and
23
his statement to you is, This will now end
24
but I think a dismissive statement is okay.
25
What did he mean by his statement,




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 392 of 465
Page 392
1
G Maxwell - Confidential
2
This will now end?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. I have no idea.
6
Q. Did you discuss with him what he
7
meant by the statement, This will now end?
8
A. I don't recall.
9
Q. Was he taking any action to ensure
10
that, quote, this will now end?
11
A. I have no idea.
12
(Maxwell Exhibit 23, email, marked
13
for identification.)
14
Q. This is an email from, if you look
15
at the chain at the top, you will see it's
16
from you to Jeffrey on January 27 and the
17
email at the bottom of the chain is from
18
Jeffrey to you on January 27.
19
He states, What happened to you and
20
your statement, question mark, question mark.
21
And you put at the top, I have not decided
22
what to do.
23
A. Uh-huh.
24
Q. Why was Jeffrey interested in you
25
making a statement to the press?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 393 of 465
Page 393
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I don't know that he was
5
interested. We made a statement and then I
6
was being advised to make an additional
7
statement and I never did.
8
Q. Was Jeffrey communicating with you
9
regularly on what additional statement you
10
might make?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. No, I've communicated with him very
14
little, as little as possible.
15
Q. Why did you feel you had to keep
16
him informed of statements you were making to
17
the press?
18
MR. PAGLIUCA: Objection to the
19
form and foundation.
20
A. I didn't feel I had to.
21
Q. Then why you were communicating
22
with him about statements you were making to
23
the press?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 394 of 465
Page 394
1
G Maxwell - Confidential
2
A. Insofar as this is the case, it's
3
really all about Jeffrey, it's not a case
4
about me.
5
Q. In 2009, did you direct your
6
lawyer, either directly or indirectly, to
7
tell Brad Edwards that you were unavailable
8
to attend a deposition?
9
MR. PAGLIUCA: Objection to the
10
form and foundation. And this is a
11
privileged communication as I understand
12
the question, what someone said or
13
didn't say to their lawyer. So don't
14
answer the question.
15
Q. Can you answer that question
16
without revealing a privileged communication?
17
A. Can you ask the question again?
18
Q. In 2009, did you direct your lawyer
19
to tell Brad Edwards that you were
20
unavailable to attend a deposition?
21
MR. PAGLIUCA: Same instruction.
22
Q. Did you make any statement in 2009
23
to anybody that you were unavailable to
24
attend a deposition?
25
A. My mother was sick and I don't



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 395 of 465
Page 395
1
G Maxwell - Confidential
2
recall exactly the sequence of events but
3
what sequence of events do exist are -- was
4
handled by my lawyers.
5
Q. What is your understanding of
6
Jeffrey Epstein's nonprosecution agreement?
7
A. I have no idea.
8
Q. Do you have an understanding of the
9
co-conspirators listed in the nonprosecution
10
agreement?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. I have no knowledge of his
14
agreement, whatever that is.
15
Q. Do you know, you mentioned earlier
16
today that
was one of the listed
17
co-conspirators.
18
Do you know who the other
19
co-conspirators are in the nonprosecution
20
agreement?
21
MR. PAGLIUCA: Objection to the
22
form and foundation.
23
A. I do not know.
24
Q. What did Jeffrey Epstein tell you
25
about the nonprosecution agreement?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 396 of 465
Page 396
1
G Maxwell - Confidential
2
A. I don't think I've ever discussed
3
it with him.
4
Q. How did you come to learn that
5
was covered by the
6
nonprosecution agreement?
7
A. I believe I read it in the press.
8
Q. Did you have any discussions with
9
with about the nonprosecution
10
agreement?
11
A. I have not had any discussions with
12
13
Q. When is the last time you spoke to
14
?
15
A. Maybe 2005, 2006 maybe.
16
Q. And same with
,
17
when is the last time you recall speaking
18
with
?
19
A. Probably even more time before
20
that, maybe -- I've never had communications
21
really with
22
Q. I'm sorry, I didn't hear that.
23
A. I never had communications with
24
her.
25
Q. You were working for Jeffrey at the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 397 of 465
Page 397
1
G Maxwell - Confidential
2
same time
was also working for Jeffrey,
3
isn't that correct?
4
A. I didn't know what
did for
5
Jeffrey so I didn't characterize what her
6
relationship or work or not was and I was
7
still helping him with his construction
8
projects and the like but I never crossed
9
paths with
10
Q. What did you think
was doing
11
for Jeffrey?
12
A. I have no idea what
was doing
13
for Jeffrey.
14
Q. Did you observe
at any of
15
Jeffrey's houses while you were there?
16
A. She was at the house on occasion.
17
Q. What would she be doing there?
18
A. I have no idea.
19
Q. Did you know if she lived at his
20
houses?
21
A. I have no idea.
22
Q. Did you ever go into a bedroom and
23
see her belongings at one of the houses?
24
A. Not that I recall, no.
25
Q. I'm going to mark this as Maxwell



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 398 of 465
Page 398
1
G Maxwell - Confidential
2
Exhibit 24?
3
(Maxwell Exhibit 24, email, marked
4
for identification.)
5
Q. You can see at the top of the first
6
page which is GM 0001, it's dated January 3,
7
2015 from you to the
8
Is that
who we
9
referred to today?
10
A. Yes.
11
Q. And can you tell me, it says, Have
12
some info. Call me when you have a moment.
13
What is redacted there?
14
A. I don't recall, I'm sorry.
15
Q. Do you know why there is a
16
redaction on this document?
17
A. You would have to confer with my
18
lawyers.
19
Q. What did you discuss on that call?
20
A. I don't have any specific knowledge
21
of that call.
22
Q. So the call is being made on
23
Saturday, January 3, 2015?
24
MR. PAGLIUCA: Objection to the
25
form and foundation.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 399 of 465
Page 399
1
G Maxwell - Confidential
2
Q. The document states, it's Saturday
3
January 3, 2015. You issued your press
4
release on January 2, 2015.
5
Were you discussing with
6
the subject of Virginia Roberts during
7
these calls?
8
MR. PAGLIUCA: Objection to the
9
form and foundation.
10
A. I don't know if I spoke to him.
11
Q. I would like you to turn to GM 0002
12
and the bottom chain says
,
13
Saturday January 3, to
re, and he says
14
let me know when we can talk. Got some
15
specific questions to ask you about Virginia
16
Roberts.
17
Do you recall having a conversation
18
with
about Virginia Roberts in
19
or around early January of 2015?
20
A. I don't know if we actually spoke.
21
Q. Did you ever speak to
22
about Virginia Roberts after you issued your
23
statement on January 2, 2015?
24
A. I know that we did speak at some
25
point but I don't recollect when we spoke.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 400 of 465
Page 400
1
G Maxwell - Confidential
2
Q. What did you talk about?
3
A. Just what a liar she is.
4
Q. What did he say to you?
5
A. What a liar she is.
6
Q. Did he tell you why he thought she
7
was a liar?
8
A. I don't think he told me why she
9
was a liar. The substance of everything that
10
she said was a lie with regard to him.
11
Q. What did you say to him?
12
A. She is a liar.
13
Q. That was the whole conversation, it
14
was you said to him, she is a liar and he
15
said to you she say liar and did you discuss
16
any of the details about what those lies
17
were?
18
A. I don't recollect.
19
Q. Was that only one conversation you
20
had?
21
A. I don't recollect. I don't
22
recollect actually the conversation but other
23
than -- in detail other than we both said she
24
was a liar.
25
Q. Do you regularly communicate with



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 401 of 465
Page 401
1
G Maxwell - Confidential
2
?
3
MR. PAGLIUCA: Objection to the
4
form and foundation.
5
A. What do you mean by regularly.
6
Q. Do you email with him once a month,
7
once every two months or text him or call
8
him?
9
A. No, we are not in that type of
10
regular touch.
11
Q. Do you travel with him regularly?
12
A. I don't know, I have traveled with
13
him. We have traveled together but regularly
14
is not a correct characterization.
15
Q. Do you travel with him more than
16
once a year?
17
A. There is no standard. There is no
18
set pattern. The answer to that was no.
19
Q. Have you ever observed him with any
20
underage, any women, female under the age of
21
18, interacting, that's not a child or a
22
family friend, interacting for the purposes
23
of a sexual relationship with that
24
individual?
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 402 of 465
Page 402
1
G Maxwell - Confidential
2
form and foundation.
3
A. I've never seen
interact in
4
any way of that nature.
5
Q. Have you ever gone to dinner with
6
him with any individual under the age of 18
7
that's not a family member or friend of yours
8
that is under the age of 18?
9
MR. PAGLIUCA: Objection to form
10
and foundation.
11
A. We've been to dinner all the time,
12
I am not not sure who is at dinner with us, I
13
can't testify to that.
14
Q. Has he ever brought a female under
15
the age 18 that's not a relative of his --
16
A. He has children.
17
Q. I said not relatives.
18
A. I can't possibly testify to who he
19
comes to dinner with, I wouldn't recall.
20
Q. To your knowledge, has he ever had
21
a relationship with any female under the age
22
of 18 for purposes of a romantic relationship
23
to your knowledge?
24
A. I can't testify to
25
relationship.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 403 of 465
Page 403
1
G Maxwell - Confidential
2
Q. You haven't observed that?
3
A. No.
4
Q. Have you talked to
5
about coming to testify at trial in this
6
case?
7
A. No.
8
Q. When was the last time you
9
communicated with
10
A. 1994, 1995.
11
Q. I believe earlier, did you say that
12
you -- when is the last time you've been to
13
his home in
14
A. I said -- you asked me if I stayed
15
the night.
16
Q. I'm asking you a different
17
question. When is the last time you have
18
been to his home in
19
A. Roughly the same time, in the
20
middle of the '90s sometime, mid '90s.
21
Q. Not in the years 2000 to 2002?
22
A. Mid '90s.
23
Q. Have you ever communicated with any
24
representative of
25
MR. PAGLIUCA: Objection to the



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 404 of 465
Page 404
1
G Maxwell - Confidential
2
form and foundation.
3
A. I mean I've been to his -- in the
4
mid '90s, I would have communicated with
5
people who worked for him.
6
Q. Have you communicated with
7
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 the
12
form and foundation. You've asked this
13
question, by the way, earlier on today.
14
A. Again, I testified that there are
15
people who from time to time in the privacy
16
of a swimming pool have maybe taken a bikini
17
top off or something but it's not common and
18
certainly when I was at the house I don't
19
really recollect seeing that kind of
20
activity.
21
Q. Have you ever smoked cigarettes?
22
A. Yes.
23
Q. Have you ever smoked cigarettes
24
with Virginia Roberts?
25
A. I don't recall smoking cigarettes



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 405 of 465
Page 405
1
G Maxwell - Confidential
2
with Virginia Roberts.
3
Q. I'm marking this as Maxwell 25.
4
(Maxwell Exhibit 25, email, marked
5
for identification.)
6
Q. I'm showing you what has been
7
marked as Maxwell 25.
8
This is an email dated January 11,
9
2015 at the top?
10
Do you see that that from Jeffrey
11
to you?
12
A. Uh-huh.
13
Q. And then below there is an email
14
from
to you and cc'ing
15
on January 11, 2015.
16
Do you see that?
17
A. Uh-huh.
18
Q. It says, Dear Ghislaine, as you
19
know I have been working behind the scenes
20
and this article comes from that. It helps
21
but doesn't answer the VR claims. I will get
22
the criminal allegations out. This shows the
23
MOS will print truth, not just a VR voice
24
piece. We can only make the truth by making
25
a statement.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 406 of 465
Page 406
1
G Maxwell - Confidential
2
What did he mean when he said, I
3
will get the criminal allegations out, what
4
was he referring to?
5
MR. PAGLIUCA: Objection to the
6
form and foundation.
7
A. I have no idea.
8
Q. Were there criminal allegations
9
about Virginia that either your lawyer or
10
were leaking to the press?
11
MR. PAGLIUCA: Objection to form
12
and foundation.
13
A. I have no idea.
14
Q. Did you ask him what he meant when
15
he said, I will get the criminal allegations
16
out?
17
A. I don't recollect the conversation.
18
Q. Did you direct him to leak to the
19
press criminal allegations about Virginia
20
Roberts?
21
A. I already testified that I have no
22
knowledge of what you are asking me.
23
Q. Were you copied on this email,
24
correct?
25
A. I was.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 407 of 465
Page 407
1
G Maxwell - Confidential
2
Q. Did Jeffrey Epstein assist in
3
obtaining information about criminal
4
allegations relating to Virginia Roberts?
5
MR. PAGLIUCA: Objection to form
6
and foundation.
7
A. I have no recollection.
8
Q. Did
assist in
9
obtaining information regarding criminal
10
allegations of Virginia Roberts?
11
MR. PAGLIUCA: Objection to form
12
and foundation.
13
A. I have no knowledge of that.
14
Q. Did you ever discuss that with
15
16
A. Discuss what?
17
Q. Criminal allegations about Virginia
18
Roberts.
19
A. I don't believe I have.
20
Q. Have you ever discussed allegations
21
relating to --
22
Q. Do you know if Jeffrey Epstein had
23
any relationship with the U.S. government
24
either working for the CIA or the FBI in his
25
lifetime?



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 408 of 465
Page 408
1
G Maxwell - Confidential
2
MR. PAGLIUCA: Objection to the
3
form and foundation.
4
A. I have no knowledge of that.
5
Q. Do you know if Jeffrey Epstein has
6
any friends that are in the CIA or FBI?
7
MR. PAGLIUCA: Objection to the
8
form and foundation.
9
A. I have no idea.
10
Q. Are you aware of an investigation
11
of Jeffrey Epstein in the early '80s relating
12
to the SEC?
13
MR. PAGLIUCA: Objection to the
14
form and foundation.
15
A. I have no knowledge of that.
16
Q. Are you aware that Jeffrey Epstein
17
has told people that he worked for the
18
government to recover stolen funds?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I don't recall conversations about
22
that.
23
Q. Has he ever told that you he worked
24
for the U.S. government?
25
A. I don't recollect that.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 409 of 465
Page 409
1
G Maxwell - Confidential
2
Q. You don't recollect or has he never
3
told you that?
4
A. I have no knowledge, I don't
5
recollect him telling me he worked for the
6
government.
7
Q. Does Jeffrey Epstein have any
8
affiliation with the Israeli government?
9
MR. PAGLIUCA: Objection to the
10
form and foundation.
11
A. I have no knowledge of that.
12
Q. Do you know if he ever performed
13
any work for the Israeli government?
14
A. I have no knowledge of that.
15
Q. Have you ever visited Israel with
16
Jeffrey Epstein?
17
A. I'm sorry, I don't recollect.
18
Q. You've seen the flight logs that I
19
provided you today. Are there, during the
20
time you worked for Jeffrey Epstein, were
21
there times that you flew on commercial
22
flights rather than Jeffrey Epstein's planes?
23
A. Yes.
24
Q. How often did that occur?
25
A. Decently.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 410 of 465
Page 410
1
G Maxwell - Confidential
2
Q. Were there other flights that you
3
recall flying on with Jeffrey Epstein that
4
were on flights that -- where
was
5
not the pilot?
6
A.
was not always the
7
pilot.
8
Q. How many planes did Jeffrey Epstein
9
have during the time you were with him?
10
MR. PAGLIUCA: Objection to the
11
form and foundation.
12
A. So you need to give me a date
13
range.
14
Q. During the time period of 1992
15
through when you left your employment which I
16
think you said was in 2009?
17
A. So in the '90s he had one plane and
18
at some point in the 2000s he had two planes
19
but I can't testify to anything past 2002,
20
2003, what happened to his planes after that.
21
Q. Do you know what travel agency, if
22
any, Jeffrey would use when he would send
23
someone, for example, you or one of his other
24
employees on a flight somewhere? Did he use
25
a particular travel agency to make those



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 411 of 465
Page 411
1
G Maxwell - Confidential
2
arrangements?
3
A. I don't recall.
4
Q. Were you ever responsible for
5
making those arrangements for other
6
individuals?
7
A. I don't recall making flight
8
arrangements.
9
Q. Was it a New York travel agent that
10
you would use for those arrangements?
11
A. Again, we are talking 16, 17, 18
12
years. I just don't recall anything to do
13
with travel agents.
14
Q. Would Jeffrey Epstein ever fly, for
15
example,
on a commercial flight
16
to meet you in New Mexico?
17
MR. PAGLIUCA: Objection to the
18
form and foundation.
19
A. I can't testify to that.
20
Q. Do you recall a trip where you met
21
in New Mexico?
22
A. No, I don't recall any specific
23
trip, no.
24
Q. Why would you be sent to New
25
Mexico, is there a reason why you would go



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 412 of 465
Page 412
1
G Maxwell - Confidential
2
there in the course of the work you were
3
doing for Jeffrey?
4
MR. PAGLIUCA: Objection to the
5
form and foundation.
6
A. I was never sent. I had a job to
7
do and I would have to go to New Mexico for
8
work.
9
Q. Would
assist in that
10
project?
11
MR. PAGLIUCA: Objection to the
12
form and foundation.
13
A. No. The project was largely
14
complete, largely complete by the end -- I
15
don't remember the dates exactly but it was
16
largely complete by the 1990s, 2000s.
17
Q. Do you know why
would
18
be going to New Mexico to meet you?
19
MR. PAGLIUCA: Objection to the
20
form and foundation.
21
A. I don't know. She worked for
22
Jeffrey.
23
MR. PAGLIUCA: I think we are out
24
of time, counsel.
25
THE VIDEOGRAPHER: It's true.



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 413 of 465
Page 413
1
G Maxwell - Confidential
2
MS. McCAWLEY: I will state for the
3
record there were questions today that
4
remain unanswered because the witness
5
has been instructed not to answer those
6
questions and we will be raising our
7
objections with the court to be able to
8
have those questions answered in the
9
near future.
10
MR. PAGLIUCA: So we are clear, we
11
are designating this entire deposition
12
as confidential under the protective
13
order. That would cover the paralegal
14
whose been present as well as the court
15
reporter and the videographer and all
16
the lawyers in the room.
17
THE VIDEOGRAPHER: This concludes
18
today's proceedings. We are off the
19
record at 6:43 p.m.
20
(Time noted: 6:43 p.m.)
21
22
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 414 of 465
Page 414
1
2
- - -
3
I N D E X
4
- - -
5
6
GHISLAINE MAXWELL PAGE
7
By Ms. McCawley 4
8
9
- - -
10
E X H I B I T S
11
- - -
12
MAXWELL EXHIBIT PAGE
13
Exhibit 1 police report 24
14
Exhibit 2 email 33
15
Exhibit 3 transcript 71
16
Exhibit 4 photo 109
17
Exhibit 5 photo 113
18
Exhibit 6 flight logs 117
19
Exhibit 7 photo 133
20
Exhibit 8 photo 143
21
Exhibit 9 message pad pages 147
22
Exhibit 10 email 209
23
Exhibit 11 photo 259
24
Exhibit 12 documents 263
25
Exhibit 13 documents 312



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 415 of 465
Page 415
1
2
MAXWELL EXHIBIT PAGE
3
Exhibit 14 email 345
4
Exhibit 15 email 348
5
Exhibit 16 email 348
6
Exhibit 17 email 361
7
Exhibit 18 email 363
8
Exhibit 19 email 365
9
Exhibit 20 email 367
10
Exhibit 21 email 384
11
Exhibit 22 email 390
12
Exhibit 23 email 392
13
Exhibit 24 email 398
14
Exhibit 25 email 405
15
16
17
18
19
20
21
22
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 416 of 465
Page 416
1
2
CERTIFICATE
3
4
5
I HEREBY CERTIFY that the witness,
6
GHISLAINE MAXWELL, was duly sworn by me and
7
that the deposition is a true record of the
8
testimony given by the witness.
9
10
_______________________________
11
Leslie Fagin,
Registered Professional Reporter
12
Dated: April 22, 2016
13
14
15
(The foregoing certification of
16
this transcript does not apply to any
17
reproduction of the same by any means, unless
18
under the direct control and/or supervision
19
of the certifying reporter.)
20
21
22
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 417 of 465
Page 417
1
2
ACKNOWLEDGMENT OF DEPONENT
3
I, , do hereby
4
certify that I have read the foregoing pages,
and that the same is a correct transcription
5
of the answers given by me to the questions
therein propounded, except for the
6
corrections or changes in form or substance,
if any, noted in the attached Errata Sheet.
7
8
9
GHISLAINE MAXWELL DATE
10
11
Subscribed and sworn
to before me this
12
day of , 2016.
13
My commission expires:
14
Notary Public
15
16
17
18
19
20
21
22
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 418 of 465
Page 418
1
2
- - - - - -
E R R A T A
3
- - - - - -
PAGE LINE CHANGE
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 419 of 465

















































































































































































































































































































































































































































































Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 420 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 421 of 465
Page 3
articles 206:21
231:15 368:21
aside 74:23 133:21
147:21 176:9,14
176:17,20 177:10
177:12 384:10
asked 26:14,16,25
43:3 57:2 68:4
86:22 87:14
112:21 117:2
157:15 169:9
198:15,17 232:9
269:7,8,15,21
284:16 286:24
337:18 338:8,10
358:21 360:16,17
363:10 366:11
370:2,8 375:19
403:14 404:12
asking 9:14 14:24
14:24,25 15:6,7
16:3,4 20:3,8
21:12,15 24:6
25:22 26:7 32:11
33:13 37:23 39:24
41:10 49:14 50:9
51:18,19,21,23,25
52:3,20,25 53:2,7
53:8,20,21 62:8
67:4 83:3 85:21
86:4 88:2,3 90:11
94:2,20 96:4,9,11
96:16 97:9,25
99:2 108:17
112:22 116:16
117:11 126:19,21
137:24,25 138:13
138:24 139:14
148:24 150:5
155:20 161:2
171:11,16 173:19
173:20,21 174:20
174:21 175:10
177:10,13 178:2
178:19,23,25
179:2,3,4,6,7,20
180:16 181:14
183:17 191:19
192:21 196:15,21
197:13,20 199:14
199:15,17 200:10
200:20 201:5
203:17 212:16
216:20 220:21
224:24,25 237:16
237:17,22 238:21
240:19,22,23
241:2 242:9
244:15,17,22
245:3 250:10
268:2,4,6 276:12
276:15 277:10,16
277:20 280:6
281:20 282:3,4,7
283:8 284:23,24
285:6 286:20
287:14,21 290:10
293:8,13 299:14
303:4 307:9
316:13 323:24
325:23 328:16
332:23 336:25
338:5 343:14
348:5 350:17
353:12 357:15
358:4,8 360:9
363:7,8 364:9
366:17 383:13
386:9,15 403:16
406:22
asks 259:18
aspect 228:6
assault 207:24
assaulted 56:17
83:18 87:21 89:10
90:2
asserting 88:8
274:12
assist 77:10 118:14
407:2,8 412:9
assistance 100:5
assistant 5:18
63:21 255:4,20
268:19 315:7
320:24 321:16
assistants 31:11
92:13 254:19
255:2,5,13,18
assume 116:16
284:6
assumed 11:9
assumes 43:25
241:11 343:11
assuming 285:25
286:3
assumption 166:19
219:18
attached 210:3
417:6
attend 377:2,11
394:8,20,24
attendant 213:20
213:20 214:25
attendants 310:10
attended 377:12
attention 29:4 73:2
117:16 119:22
120:2,12 142:2
144:13,18,23
148:20 149:15
150:9 151:17,21
153:24 158:4,16
165:10 166:21
263:12,19 319:15
319:19 346:18
361:14 366:4
attest 302:18
attorney 186:2
309:5
attorneys 2:4,9,13
2:17 346:12 375:3
attractive 191:11
192:13
author 327:23
authored 260:5
authority 389:12
authorize 273:6,11
authorized 347:9
availability 325:13
available 160:2
187:2 325:2,6
346:22 347:19
avenu 2:17
avenue 1:17,24
2:10 3:11 264:12
average 78:16,22
91:5
avoid 346:21
373:14
awal 374:25
aware 14:6 39:3
49:8,15,16 55:5
82:24,25 83:8,16
83:24,25 84:6
87:8,19,24 88:3,6
89:7 99:19 107:24
111:16 113:11
115:17,19 134:11
164:6 167:16
169:10,12,14,16
169:17 170:3,14
171:25 172:2,6
181:6 183:25
184:4 198:3
223:11 224:9
225:9,21,23
231:11 250:13,21
250:24,25 251:3,4
251:7,11 255:20
256:6,8 275:8,21
276:5,15,25
277:20 278:4,6,18
278:25 279:3,12
279:22 280:5,8
289:16 298:15
318:3 338:14
344:3 372:22
379:10,16 381:19
384:9,18 408:10
408:16
awful 19:4
B
b 212:21 224:2
414:10
babies 338:21
baby 336:12,22
337:4,12,18,25,25
338:9,11,19,23,24
339:3,4,6
back 8:13 11:8,15
20:18 22:5 26:17
30:2 35:19 53:10
54:12,21,22 68:2
72:16 73:24 86:19
101:10 103:9
105:21 112:4
115:11 118:5
127:4 131:17
132:13 133:24
141:19 145:15
148:7 156:15
166:22 168:11
182:3 183:16
208:17 235:22
246:12,15 247:12
247:18 250:19
256:16 261:14
265:9,25 294:15
319:17 327:11
333:13,14 340:2,5
340:10,12 341:17
343:3 345:22
373:10,12 377:10
377:13 386:24
388:6,6
backed 240:9
background 10:17
11:5,12
bad 180:24
band 129:21
137:14
banging 228:25
bangkok 131:4
140:9 264:19
265:4,5,7
202:10
204:2 274:10
275:17,19 346:11
347:24 348:24



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 422 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 423 of 465
Page 5
245:20 249:17
291:7 321:19
339:7
bringing 17:4
48:19 49:2 99:19
309:24 380:6,15
british 211:4
159:25
161:22
brought 16:21
18:17 27:2,3
98:13 99:15
146:22 147:3
155:4 221:14
224:12 248:7
249:12,22 254:16
309:23 321:14
339:13 382:5
383:3 402:14
99:15
116:21 166:25
167:7 379:22
380:6,14
bubble 234:24
builders 12:14,15
building 12:16,20
143:20,21 144:2
bunch 230:20
burberry 233:6
business 21:18
381:7,10,14,20
388:20 389:2,15
businesses 388:25
busy 28:24 29:5
butlers 310:12
buy 111:24 341:4,9
buying 66:20
233:22
268:18
269:8,15,21,25
270:10,22 271:18
272:3,15,18
C
129:17
call 73:8 77:17 79:8
92:5 150:17
160:17 161:4,6
165:19,23 167:6
260:20 295:23
314:10 325:4
336:5 385:21
398:12,19,21,22
401:7
called 4:6 71:3
111:12 115:13
117:3 134:3 158:7
163:24 165:15
236:11,12 325:5
335:25 361:23
374:23 387:23
calling 80:4 160:7
164:15 165:4
239:12,18,24
240:16 241:6
296:9 362:7,25
calls 49:12 149:4
199:5 274:9 281:2
284:2 298:8 375:2
399:7
calm 181:19 207:23
campus 310:25
campuses 311:9
canada 132:6,7,21
141:21
cant 4:23 5:2 23:18
35:24 73:10 84:9
99:6,8 105:17
106:13 112:16
125:6 128:14
129:3,6 137:3
141:7 144:6 147:6
153:10 154:8
156:14 161:11
165:8 177:12
188:17 192:24
193:15,16 195:4
195:14 212:10
220:10 221:3,13
221:20 222:6
223:9 231:22
233:21 237:7
238:3,19 240:25
241:4 245:6
255:13 268:12,14
271:4,8 272:8
282:8,25 283:16
285:15 286:13
293:11 294:4
296:15 297:18
299:2,22,23 300:6
301:4,12,18 302:6
303:21,22 307:4
314:7 320:8,11
321:2 324:14
325:20 326:2
327:24 328:2
329:22 330:7
332:9,17 333:7,13
333:15 337:16
341:3,5,7 348:6
350:20 369:14
375:17 378:6
385:21 390:11
402:13,18,24
410:19 411:19
capacity 188:6
382:18 384:13
car 276:18 341:4,8
341:9,12,15,17,25
342:10,13,16
career 60:13 61:7
careful 369:2,5,16
369:19
carefully 177:10
202:2
caricature 289:22
289:24,25 290:12
290:15,15,22,25
291:16,18,21
292:2,6,16 293:10
293:11
152:2
153:12,14
carry 336:11,21
337:4,12,18,24
338:9,11,19
carrying 214:2
cars 341:16,19,23
342:3,5,21
case 1:7 6:9 7:10
21:14,21,25 27:5
49:10 94:3 103:3
103:3,6 118:20
150:8 211:15,16
211:17 238:11
283:18 335:21,22
336:2,5 343:22,25
349:2 350:3,12
352:13 360:6
373:15 374:16,23
394:2,3 403:6
404:7
cases 375:8 376:4,5
casey 152:2 153:12
153:14
cash 50:5,11,17,20
50:21
cassell 2:13 3:25,25
categorically
117:14,15 134:8
174:16 227:25
categorize 135:19
135:22
caught 275:14
cause 239:14,20,25
240:18 241:8
caused 206:22
causes 241:19
causing 245:5
ccing 405:14
celebrated 273:19
celebrating 282:17
cell 76:22,24 77:11
77:16 259:4,6
260:2 261:21
321:5,9,15 322:8
certain 68:19
certainly 54:20
99:7 138:4 148:16
315:15 322:25
368:18 404:18
certificate 416:2
certification 124:23
416:15
certify 416:5 417:4
certifying 416:19
certitude 171:23
chain 352:23
353:12,13 356:7
367:25 368:4,11
368:17 369:18
391:2,21 392:15
392:17 399:12
change 11:24 102:3
265:11 418:3
changed 10:11
214:24 251:9
345:22
changes 210:15
417:6
characterization
32:20 105:19
213:5,9 214:8,17
215:18 219:6,14
226:16 228:24
231:17 233:5
234:6 290:9
309:20 401:14
characterizations
126:7 235:12
characterize
135:16 216:14
290:8 296:15
297:2 298:13
310:4,6 311:14
321:20 338:12
375:17 397:5
characterized
228:21 236:2,5
290:7 347:10
357:2 367:18
383:8
characterizing
364:15
charge 12:9,10 31:6
49:23 51:11,12
54:8 322:7
charges 195:8
368:22



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 424 of 465
Page 6
charity 371:16
chart 118:14,20
chauffeurs 310:12
check 196:9 357:16
chef 247:4 383:11
chefs 245:12
310:11
377:2,11,12
child 23:16 38:6
42:24 43:4,7,15
43:16 106:19
165:3 173:4 181:8
401:21
children 13:20 14:8
22:25 23:17,25
30:22 90:19
107:22 168:22
170:19 180:8
183:2 184:6 339:9
402:16
china 131:4 140:9
377:18
chips 208:8
choose 244:24
382:22,24
chose 182:22
266:23
christe 2:22 3:14
chums 391:18
cia 407:24 408:6
cigarettes 404:21
404:23,25
circumcised 86:22
86:23
circumstances 63:6
328:15
circus 288:18
citizen 371:8,11,13
city 2:14 119:10
271:12
civil 20:22
clad 194:10
claimed 63:14
171:22 235:11,22
257:21
claiming 35:2
355:2
claims 102:23
106:12 108:16
179:23 201:10,20
202:6 205:5 206:4
210:19,25 211:7
213:12,13,19
251:7 405:21
clarification 358:9
clarify 7:22 8:13
9:5 36:21 257:2,3
clarity 8:4,20
cleaners 31:12
116:18
cleaning 245:12
clear 6:17 8:15,21
9:8 30:5 41:4
54:19 103:6 119:3
126:5 137:4
138:13 174:5
177:24 208:4
249:17 251:6
263:14 321:24
338:4,7,8 413:10
clearance 377:18
378:2
clearer 276:14
clearly 33:19 69:11
107:8 282:18
384:10
client 20:10
clients 380:23
104:17,23
105:3,7 106:2,4
129:20 130:3,9,14
130:18 131:4
134:7,11,15,16,22
135:7,11,15,25
136:2,8,19 137:5
137:18 138:18
139:4,15 140:11
212:14 230:8,14
266:22 267:2,8,15
267:25 268:9
301:15,21 351:9
377:3,23 378:12
376:24
377:11,12
clock 74:10,14,17
close 295:2,15
closest 294:23
295:6
closet 73:20
clothes 30:8,10
190:23
clothing 190:13,23
194:8
club 111:12 236:9
236:10,10,11,13
coconspirator 49:9
49:9
coconspirators
378:22 395:9,17
395:19
code 118:18
codes 118:15
125:20
colleague 3:20
collect 284:7,11
color 141:8 142:20
143:9
colorado 2:18
column 120:14,15
120:15 130:22
131:8,24 132:3,12
132:14 321:4,9
326:4
columns 322:19,21
com 34:12
come 11:8 13:23
14:3,10,15,19
15:2,7,15,21 16:5
45:15 51:14 54:21
54:22 73:24 77:20
77:25 78:13 79:8
103:9 112:4
114:20 154:10
156:20 157:13,16
161:22 162:16,23
163:3,17 167:14
219:9,25 223:21
224:19,23 232:22
246:12,14,15
247:12,20 249:9
250:18 254:20
255:6 269:8,16,22
272:22 293:16,23
325:2 333:22
351:7 363:18
364:3,10,21 366:7
366:11,14 377:10
382:17 396:4
comes 36:23 228:14
402:19 405:20
comfortable 25:12
86:14 222:23
coming 27:10 29:19
78:14 153:19
160:19 163:25
226:14 247:18
329:8,16,25
330:10 350:15
368:6 380:10
403:5
commencing 1:17
comment 29:22
90:5 176:20
220:10,11 294:4
commercial 409:21
411:15
commission 417:13
commits 353:24
committed 344:12
344:16,22 346:24
386:4
common 199:8
200:3 404:17
communicate
222:18 355:17
400:25
communicated
393:13 403:9,23
404:4,6
communicating
356:10 393:8,21
communication
199:6,24 284:2
394:11,16
communications
199:13,15 200:2
274:9,15,20 363:9
396:20,23
company 372:15,15
387:22,25 388:4
388:10,17,19
389:8,8,10
compare 268:3
compel 179:15
compensation
278:9,22
competencies
248:14,15
competent 246:22
compilation 352:20
complete 10:22
273:23 412:14,14
412:16
completed 230:2
completely 227:4
337:10 367:5
complex 353:17
composite 345:10
computer 186:22
186:23 187:2,6,9
187:20,25 188:9
188:12,14 189:10
189:12 194:23
313:13,18,24
314:8,12 315:8,20
315:23 316:4,24
318:4,12,19 319:2
319:2,4 331:2,2,6
331:8,11,17,22,23
331:24 332:4,6,10
332:12,24 333:9
333:18,22 334:3,7
370:24 371:6
computers 188:19
189:2,6 319:5
330:25
concealed 191:4
conceivable 245:16
conceive 245:17
conceived 136:8



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 425 of 465
Page 7
concern 355:7,12
concerned 24:7
226:12 302:15
303:14 335:11
354:5,9 355:14,15
355:23 369:9
concerns 178:16
354:20
concludes 413:17
conclusion 25:10
49:13
condo 57:25
conduct 200:25
203:2,10,19 205:7
conducted 389:25
confer 398:17
confidential 1:11
4:1 5:1 6:1,7,14
6:15 7:1,13 8:1
9:1 10:1 11:1,7,13
11:18 12:1 13:1
14:1 15:1 16:1
17:1 18:1 19:1
20:1,14 21:1 22:1
23:1 24:1 25:1
26:1 27:1 28:1
29:1 30:1 31:1
32:1 33:1 34:1,6
35:1 36:1 37:1
38:1 39:1 40:1
41:1 42:1 43:1
44:1 45:1 46:1
47:1 48:1 49:1
50:1 51:1 52:1
53:1 54:1 55:1
56:1 57:1 58:1
59:1 60:1 61:1
62:1 63:1 64:1
65:1 66:1 67:1
68:1 69:1 70:1
71:1 72:1 73:1
74:1 75:1 76:1
77:1 78:1 79:1
80:1 81:1 82:1
83:1 84:1 85:1
86:1 87:1 88:1
89:1 90:1 91:1
92:1 93:1 94:1
95:1 96:1 97:1
98:1 99:1 100:1
101:1 102:1,19
103:1 104:1 105:1
106:1 107:1 108:1
109:1 110:1 111:1
112:1 113:1 114:1
115:1 116:1 117:1
118:1 119:1 120:1
121:1 122:1 123:1
124:1 125:1 126:1
127:1 128:1 129:1
130:1 131:1 132:1
133:1 134:1 135:1
136:1 137:1 138:1
139:1 140:1 141:1
142:1 143:1 144:1
145:1 146:1 147:1
148:1 149:1 150:1
151:1 152:1 153:1
154:1 155:1 156:1
157:1 158:1 159:1
160:1 161:1 162:1
163:1 164:1 165:1
166:1 167:1 168:1
169:1 170:1 171:1
172:1 173:1 174:1
175:1 176:1 177:1
178:1 179:1 180:1
181:1 182:1 183:1
184:1 185:1 186:1
187:1 188:1 189:1
190:1 191:1 192:1
193:1 194:1 195:1
196:1 197:1 198:1
199:1 200:1 201:1
202:1 203:1 204:1
205:1 206:1 207:1
208:1 209:1 210:1
211:1 212:1 213:1
214:1 215:1 216:1
217:1 218:1 219:1
220:1 221:1 222:1
223:1 224:1 225:1
226:1 227:1 228:1
229:1 230:1 231:1
232:1 233:1 234:1
235:1 236:1 237:1
238:1 239:1 240:1
241:1 242:1 243:1
244:1 245:1 246:1
247:1 248:1 249:1
250:1 251:1 252:1
253:1 254:1 255:1
256:1 257:1 258:1
259:1 260:1 261:1
262:1 263:1 264:1
265:1 266:1 267:1
268:1 269:1 270:1
271:1 272:1 273:1
274:1 275:1 276:1
277:1 278:1 279:1
280:1 281:1 282:1
283:1 284:1 285:1
286:1 287:1 288:1
289:1 290:1 291:1
292:1 293:1 294:1
295:1 296:1 297:1
298:1 299:1 300:1
301:1 302:1 303:1
304:1 305:1 306:1
307:1 308:1 309:1
310:1 311:1 312:1
313:1 314:1 315:1
316:1 317:1 318:1
319:1 320:1 321:1
322:1 323:1 324:1
325:1 326:1 327:1
328:1 329:1 330:1
331:1 332:1 333:1
334:1 335:1 336:1
337:1 338:1 339:1
340:1 341:1 342:1
343:1 344:1 345:1
346:1 347:1 348:1
349:1 350:1 351:1
352:1 353:1 354:1
355:1 356:1 357:1
358:1 359:1 360:1
361:1 362:1 363:1
364:1 365:1 366:1
367:1 368:1 369:1
370:1 371:1 372:1
373:1 374:1 375:1
376:1 377:1 378:1
379:1 380:1 381:1
382:1 383:1 384:1
385:1 386:1 387:1
388:1 389:1 390:1
391:1 392:1 393:1
394:1 395:1 396:1
397:1 398:1 399:1
400:1 401:1 402:1
403:1 404:1 405:1
406:1 407:1 408:1
409:1 410:1 411:1
412:1 413:1,12
confirm 112:23
299:18,25 300:9
301:8,14,25
303:16 356:11
359:24
confirming 356:16
connection 21:14
consensual 20:9
21:17 52:21,25
53:13 62:2,15
64:4 65:2 82:22
93:3,24 137:22
308:8
consent 54:25 63:3
353:17 354:6,21
355:18
consider 91:16,19
considerable 184:5
considerably 10:13
consideration
185:24
considered 295:4
considering 215:6
constitute 191:25
192:17
construction 12:6,7
12:8 66:19 397:7
construed 21:13
consult 186:2
consulting 11:21
contact 39:4 61:20
62:5,9,14 184:7
184:13 202:18
229:20 257:7,14
258:2,3,11,17
295:21,22 296:9
308:8,10,13
313:19 314:13,19
315:3,9,11 316:17
322:9 331:21
332:14 333:10
335:20 369:17
contacted 335:19
352:11,15 375:21
contained 70:6,12
contains 84:7
contd 168:8
contemporaneou...
284:15
contend 329:10
contest 85:21
contesting 128:19
context 60:24
235:20 245:17
246:6 272:16,17
292:12 293:12
310:14 385:14
continue 21:4,5
133:20 184:12,25
continued 86:18,20
contractor 12:12
contracts 12:15
contradict 351:13
351:19
contradictory
213:22
control 416:18
controlled 288:24
conversation 15:4
44:14 61:7 77:19
94:24 95:3 195:9
195:25 200:9
219:2 222:25
223:23 272:15,21
298:2 303:12



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 426 of 465
Page 8
338:13,20 344:18
399:17 400:13,19
400:22 406:17
conversations
195:15 200:11
272:20 303:7
338:25 339:5
408:21
convicted 172:20
172:25 173:2
181:7 359:12
cooks 31:12 116:17
245:11
coordinating 12:15
12:16 357:21
359:3,22 360:4,8
copied 209:23
370:25 406:23
copies 143:6
copy 120:9 141:14
316:3,10 318:11
368:7 371:5
corner 24:25 120:9
150:10 158:5
159:23
corporation 372:21
correct 8:10 15:15
18:16 23:25 32:13
32:20 33:8,11
35:11 84:14 96:19
101:17 135:12
139:20 148:4
198:5 206:15
214:16 218:5,6
222:14,24 225:25
227:18,19 249:7,8
252:16,19 266:12
267:17 284:9
294:19 320:3
321:25 327:17
330:14 339:19
343:3 348:15
349:22 357:2
359:13 362:2,20
363:2 365:8
368:17 371:18
373:25 374:7
378:23 383:20
397:3 401:14
406:24 417:4
corrections 417:6
correctly 129:19
219:16 222:2
cost 341:10
couch 372:13
couldnt 42:8 43:14
135:22 153:16
157:20 267:12
268:13 297:8,21
297:25 299:15
304:12 305:8
306:6 314:17
323:12 331:14
347:16 350:8
374:10 387:15
counsel 3:16 35:5
82:16 88:7 89:5
93:6 180:13
209:18 274:14
385:15 412:24
counsels 281:10
count 84:3
country 45:15 66:7
104:25 374:11
couple 89:17
124:13 128:6
163:12 186:19
259:9 263:12
328:7
course 8:14 11:25
15:3 31:15 102:5
142:4 162:9,14
163:11 195:6,15
237:10 245:12
269:6 272:20
275:7 310:20
315:5,14 323:5
324:5 342:2
370:13 412:2
court 1:2,19 3:7,15
3:17 4:18 54:12
54:22 55:4 88:14
142:7 177:24
199:11 228:4
413:7,14
cover 34:9 71:21
230:8 353:10
413:13
covered 191:4
243:18,24 396:5
create 319:10
created 312:23
313:3,22 317:22
323:11 374:16
creating 376:4
creation 313:4,9
credible 349:3
350:5,13
cried 348:25 350:3
350:11
criminal 168:19
169:14 170:14
171:5 186:3 195:2
405:22 406:3,8,15
406:19 407:3,9,17
crisis 80:5
crossed 397:8
crying 87:3
current 259:6
currently 5:24 8:18
D
d 414:3
daily 350:16 353:7
damage 102:23
damages 103:5
damaging 240:10
240:15
268:18 269:7
269:15,21,25
270:9,22 271:5,5
271:18 272:2,8,12
272:15,18,19
272:9,22
dark 142:23
date 1:19 5:25
10:24 59:9 112:22
112:23 120:9
125:16 131:23
140:5 144:16
150:14 152:2
153:3 155:25
159:24 160:22
209:19 268:13,14
313:6 347:12,14
373:23 374:24
375:3 376:21
377:3 410:12
417:9
dated 34:6 157:20
348:18 353:6,13
356:5 362:22
363:14 366:2
384:24 390:23
398:6 405:8
416:12
dates 47:18 105:11
112:17 132:19
265:24 266:2
267:11 268:12,15
282:16 412:15
daughters 116:10
163:24
129:4 410:4,6
day 5:7 78:16,17,22
84:25 92:4,21
156:8 166:7 218:8
220:6,16 222:8
223:5 226:21,22
227:23 275:11
324:17,22 325:8
417:12
days 78:25 85:6
89:17 166:11
186:20,20 328:7
dealing 12:21
deals 371:17
dear 405:18
death 85:5
debate 179:13
december 296:10
296:14,22 297:11
298:9
decently 409:25
decide 223:25
247:9
decided 204:2
392:21
decision 285:25
decorate 146:20
decorating 11:22
146:24
decorators 31:12
245:10
deep 181:20 207:22
defamation 53:15
93:24 103:3 135:5
176:13 361:18
defamatory 210:22
210:25 211:7
defendant 2:17
103:2
defendants 1:9
defense 200:3
299:7,10
define 70:24 91:14
97:3 138:6 242:21
242:23 243:2
249:24
defined 138:14
288:21
definitely 130:17
309:8
definition 243:3
definitively 134:8
282:9,24 283:4
deflecting 367:10
degree 353:24
delay 6:18
delaying 7:16
delete 369:24 370:5
370:11,14
deleted 370:7,15,17
denies 210:19
211:2,3
dent 208:7
denver 2:18
deny 174:16 299:18
300:2,10 301:8,14
303:16



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 427 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 428 of 465
Page 10
doe 210:6,7
doesnt 26:23 44:3
114:18 127:8
128:17,21,23
133:13 141:6
165:14 177:15
178:7,8 215:3
231:6 232:12
233:8 285:23
303:13 334:25
349:19,20,24
405:21
doing 10:25 32:15
41:14,18 50:19
65:24 77:13 147:8
160:14 161:14
322:15 397:10,12
397:17 412:3
dollars 185:15,17
185:18,19,23
dont 6:18 8:17 9:5
9:6,17 11:6 16:14
16:18 17:2,15,21
20:3 21:3,14 29:3
29:18 32:7 33:23
33:24 36:9,11,18
36:23 38:8,15
39:23 40:6,14
41:3,11,19 42:2,2
43:6 44:8,13,19
44:20 45:7 46:4
47:13,18 48:5,17
48:23 49:6 52:10
54:9,15 56:14
58:23 59:5,9,11
59:14,22 60:9
61:13,18 63:15
70:20 71:5 72:11
72:16 75:11,21
77:4,5 78:14
79:19,21 80:10,12
80:17 81:3,19
88:11 94:4,11,18
94:22 95:11,18
97:6,10 98:8
100:17,21 101:23
102:2 103:14,15
103:15 104:4
105:5,14,15
106:10,11,21
110:8,20 111:22
112:2,18 113:3,19
114:13,15,17,19
117:16 118:11,20
119:5,6 120:20
121:6,11 122:6
123:8 124:3
125:10 126:6,23
127:24 128:15
130:4,9,13,16
133:2,15 134:25
136:6,13,13,15
137:13 139:2,8
140:15,18,21
141:3,6,11 142:22
143:17,19,21,22
144:12 145:17,20
146:11 147:19
148:15 149:19
151:12,15 153:7
153:13,21 155:8,9
155:10,10,11,15
156:5,13 158:9,14
160:4,11,12,13
161:10,13,19,24
162:2 164:2,20,21
165:9,21 166:10
172:10,12,17,24
172:25 180:24
181:14 183:22
185:8,11,13,13
186:5,9,14,15,20
189:6 191:19,23
191:24 193:20
194:6 195:5
197:16,17,19
200:10 205:25
206:11,23 208:8
212:4 213:20
214:11,25 215:17
216:19 218:3,13
219:5 222:9
223:18 227:11
230:20,22,25
231:6,7,23 232:4
232:17 233:20
234:2 236:22
237:9,10,22 238:3
239:4 242:12,24
244:15,24 246:20
246:21 248:6
249:8 250:14
252:8,13,13,21
253:5 254:7
255:16 260:9,10
260:23,24,24
264:8 266:14
267:11,20 268:16
268:21 270:11,14
270:17 271:12
272:7,7,13,25
275:10 278:13
280:15,18 281:15
283:18 285:7,8
286:14,21 287:25
289:19,20,21
290:5,6,8,20,21
290:24 291:5,15
291:17 292:9,11
292:11,20,21,24
293:3 295:11,13
299:3,6,12 301:5
303:6,8,10 304:24
305:2 306:8,10,12
306:17,23 307:3
307:15,23 308:19
309:13,19 311:4
311:24 312:12
313:2 318:13
319:3,8,14 322:12
322:15,23,23,25
323:4,5 326:12
327:23 328:15
332:2,8,23 333:12
334:7 338:5,20,24
339:4 340:3,6
341:5,10,10,13,16
341:17,23 342:6,8
342:9,12,18 343:7
343:13,17,19
344:9 345:7,8
347:3,8,21 348:2
348:9 349:11
350:6 352:7,8,10
352:14,25 354:14
357:12 361:19
364:24 365:21
367:17 368:10
369:18,22 370:23
372:6,8,10 376:10
376:23 377:6,8,13
378:15,19 379:9
380:4,10,17
382:24 385:18,20
386:7 387:8,20
388:11,12,13,20
388:25 389:3,6
392:8 393:4
394:13,25 396:2
398:14,20 399:10
399:20,25 400:8
400:18,21,21
401:12 404:18,25
406:17 407:19
408:21,25 409:2,4
409:17 411:3,7,12
411:22 412:15,21
door 15:23 28:25
28:25
doors 293:22
dot 349:4,4,4
doubt 111:21 124:7
134:9
doubts 268:7
129:21 137:14
138:11
downloaded 331:10
333:17,25
downs 86:7
draft 360:14
drafts 360:22,23
drank 236:3
draw 346:18
dress 68:13 233:7
236:18
dressed 213:15
driven 214:6,7
215:12,13 342:3,5
drove 16:10
57:12,15,21
57:22 61:17 237:3
303:17 304:2,8
339:15
304:15
339:8
dui 390:14
398:7 399:12
duly 4:7 416:6
duties 11:24 68:7
105:16 116:19
E
e 4:6,6 168:4,4,6,6
414:3,10 418:2
earlier 68:5 133:25
141:16 168:17
229:2 255:2
280:20 282:11
283:9 286:23
295:3 298:22
299:13 313:10
327:14 330:13,24
339:16 346:11
361:7 372:2
377:16 395:15
403:11 404:13
early 91:25 361:24
362:6,23 399:19
408:11
earn 60:20
easier 119:18
142:22 231:13
east 2:4,17 5:24
eat 136:18
editor 353:16
edwards 2:8,11
3:23,23 6:18 7:3,8
151:19 158:3
373:25 374:2,4,13
374:17,19,22,25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 429 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 430 of 465
Page 12
313:11 315:22
330:10,25 331:3
334:22 336:22
337:4 382:6 383:3
395:6 404:10
409:22
equity 209:21
errata 417:6
error 326:16
espsteins 30:11
esquire 2:5,6,11,13
2:18,19
establish 231:22
248:3 250:19
established 60:21
192:9 224:8
246:21 249:15
250:6,15 251:8
254:14,15 383:21
estimate 296:20
120:17 122:17
123:23 124:18,20
124:21,21 125:23
132:14
europe 65:22
108:20 144:3
57:21,22 58:12
event 31:4
events 26:22 395:2
395:3
everybody 293:11
332:16
evidence 44:2
180:25 241:12
343:12
exact 47:18 59:9,22
61:7 104:4 105:11
110:15 298:2
377:8
exactly 13:3 17:16
48:5 59:15 72:25
105:15 106:11
172:24 179:21
185:8 186:9
242:19 270:11,14
275:10 277:11
283:14 289:4
297:21 319:8
333:12 348:7,12
354:18 375:18
377:6 378:19
385:22 395:2
412:15
exaggerator 177:7
examination 4:10
168:8
examined 4:8
example 68:22 91:6
92:6 101:24
118:16,19 155:21
180:5 296:4
314:11 318:15
372:21 410:23
411:15
examples 182:7,8
excellent 60:18
excerpts 148:2
excess 340:18,24
343:5,10,17
exciting 207:11
exclude 274:15
excused 6:9
executed 186:7,11
186:15,16 187:15
188:21
exercise 50:22
60:16 245:11
246:18 247:5,13
248:7,17 249:9,18
250:11
exhibit 24:20 33:25
34:4 71:17,20
83:6,13,13 109:20
109:23 113:21
117:19 133:6
141:14 143:4,10
147:23,25 209:13
259:11,20,21
263:8,14 266:11
266:14 273:5
312:15 345:11,12
348:19 350:24
361:2 363:12
365:23 367:22
384:21 390:21
392:12 398:2,3
405:4 414:12,13
414:14,15,16,17
414:18,19,20,21
414:22,23,24,25
415:2,3,4,5,6,7,8
415:9,10,11,12,13
415:14
exhibits 168:15
273:4
exist 395:3
existed 320:6
323:15
expect 119:6
expected 244:5
expensive 233:6
experience 89:19
223:24 277:2
expires 417:13
explain 4:12 150:19
170:22 195:7,8,11
323:12
explained 18:6
25:11
explore 61:2
extent 20:8 21:12
21:16 52:20 142:9
199:4,22 200:5
274:8 280:25
283:25 385:16
extra 60:11 61:5
extremely 108:6
240:7,9
F
f 168:4
fabrication 134:14
135:9 215:23
fact 32:17 78:5
84:10 102:25
212:16 214:8
240:14 241:15,17
301:21 312:6
345:4 346:19
facts 43:25 241:11
343:11
factual 88:8 91:3
359:10
factually 34:19
346:9 348:14
fagin 1:19 3:15
416:11
failed 374:2,25
375:2,15
fair 103:19 135:14
178:6,13 245:8
308:19 356:6
fake 207:10 273:23
374:15 376:4
false 137:6 180:6,7
206:5 228:12
229:10 334:12
351:8 352:2
368:22
falsehood 174:14
174:24 282:18
falsehoods 174:15
familiar 24:10,15
55:17 73:6,6
100:20 114:8
149:12,14 264:14
312:19,21 375:22
387:22 388:9,17
388:22 389:8
family 30:22 116:9
339:14 351:7,13
351:18,25 352:12
352:15 382:10
401:22 402:7
famous 111:15
235:24
fantasist 19:4 177:7
far 24:7 72:16
120:9 198:9
214:12 225:9
226:12 384:12
2:8 55:18
55:20,24 56:6,7,8
56:10,14 62:21
fashion 184:20
fast 138:25
fat 206:6
father 101:5 184:16
214:6 215:12
fbi 318:3 407:24
408:6
fe 144:24,25 145:15
145:15 146:6
148:12,14,16,17
february 6:2
348:18,23
federal 103:7
325:15
federally 129:5
212:2
feel 23:11 241:20
274:13 393:15,20
feeling 229:3
fees 343:22
feet 60:5 86:18
felony 353:24
felt 184:18,23
female 6:3 8:24 9:6
9:10,12,14,15,18
9:20 10:3 12:22
14:2 21:9 22:8,12
22:17 23:7,14,23
25:16 27:22 28:20
29:7,15 33:13
63:17 116:17
124:19 157:5,9,12
163:17 164:14,16
165:5 246:16
249:12 308:25
336:11,21 337:3
337:12 401:20
402:14,21 404:9
females 21:24
22:19 25:23 26:7
26:14 27:10 29:24
45:12 66:24 67:6
95:6,17 98:12,17
98:22 160:17
161:6 162:16,20
163:3 189:16,24





Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 431 of 465
Page 13
190:7,8,12,19
191:22 192:23
222:5 223:21
244:8,13,18
245:20 339:7
fiction 274:3
fictional 274:3
fictitious 31:3
230:11
figure 357:20
358:19 376:6
figures 210:16
filed 296:17,18
filing 346:19
filings 12:11
fill 383:17
filled 247:23
final 8:3,16 34:17
166:23 346:7
financial 103:2
341:11
find 31:16,20 73:10
83:13 95:9 110:17
111:3 151:13
210:3 248:13
249:7 310:16,18
311:9 312:3,9
316:25 325:21
382:21 383:9,17
finding 72:15 103:4
310:8,14
fine 7:21 11:8 119:5
finish 10:19 94:12
111:18 174:4
223:13
finished 96:19
firm 207:21 307:24
374:18,20
first 6:3 8:23 9:4,14
9:15,25 11:9,19
11:21 16:12,15,24
17:3 18:14,14
19:3,10 26:3,15
26:20 28:2,22
33:3 34:9,25 37:3
37:13,24 38:2,5,7
38:13,16 41:3
42:18,24 43:4,13
44:8 45:5 47:17
59:8 70:5 74:7
76:18 86:7 94:19
97:2 101:3 106:22
118:17 119:21
120:13 143:17
150:5 151:22
164:20 167:5
191:6 192:8 193:9
203:14 207:6
213:4,5 214:9,14
214:14,17 215:25
216:9 219:14
220:6,14 225:21
226:16,22 227:23
228:13,17,20,21
229:5,11,25
236:21 254:10
258:20 263:19
264:22 265:25
266:21 267:22
270:9 292:9
300:11,18,20
321:4,8 325:5
327:3 335:16
345:7 361:17
363:17 398:5
fistos 2:8
fits 289:3,5,11
five 79:2 85:23 86:7
166:11 298:11
375:16
fiveminute 65:14
256:10
flagged 119:17
flat 134:14 135:9
fled 346:20 348:4
flew 106:11 122:4
123:6 124:4
127:16,22 137:11
230:9 409:21
flexner 1:16 2:3
3:13,22
flight 44:11 106:4
117:19 118:9
120:4,7 121:3,3,7
121:9 122:16,24
123:21 124:8,12
125:8,13 126:16
126:24 127:2,3,7
127:22 128:18,20
128:21,24 130:2,7
130:9,17 139:10
140:24 141:2,4,17
144:14 147:7,13
147:19 148:12,13
266:7 276:18
377:15,16,22,23
378:20 409:18
410:24 411:7,15
414:18
flights 44:6,9
125:11,12 133:3
137:2 147:11,17
378:12 409:22
410:2,4
flip 156:15 157:17
floor 264:12
florida 2:5,10 225:9
250:7 254:18
319:20 320:23
321:3 322:18
323:8,19 324:2,11
325:16 326:15
353:17,20,21
354:6,21 355:4,8
355:13,19
flown 41:24 42:4
47:7,9,11 104:16
104:22 130:17
135:13 230:13
fly 47:2 121:12,19
121:25 135:10
411:14
flying 121:8 122:6
122:8,25 123:9
125:24 126:12,24
127:11 130:14
131:3 132:18
148:10,16 410:3
focus 302:16
focused 197:18
fold 145:25
folded 146:4
follow 281:10
following 219:16
281:24
follows 4:9 168:7
foot 192:16 243:25
force 124:19
129:15
foregoing 416:15
417:4
foreign 98:12,21
99:7,10,14,22
100:6 380:15
foreigner 99:2
foreman 2:16
forensically 370:25
foreskin 86:24
forget 5:7
forgive 229:6
form 6:5 9:2 12:2
12:24 13:13 14:4
14:12,20 15:11,16
15:24 16:7 18:3
18:18 19:12,19,24
22:22 24:2,13
25:25 26:9 27:12
27:24 29:9 32:4
32:25 33:16 37:5
37:14 39:6,13,19
40:3,12 41:15
42:21 43:2,17,24
45:16,23 46:8,19
47:22 48:3,8,15
48:21 49:4,11,21
50:7,14 51:3,8,16
52:5,18 56:3,12
56:18,24 57:9,16
58:4,9,15,19 60:7
61:22 63:7,12
64:13 67:3 68:10
68:16 69:19 70:4
70:9,15 71:14
74:6 75:16 76:15
77:3,23 78:19
79:4,11,18,24
81:2,7,13,24 82:6
82:13 83:21 84:20
87:13 89:14 92:8
92:17,25 93:11
96:25 97:19 98:16
98:25 99:18 100:2
100:13 102:13
106:6 109:5,10,16
116:12,23 117:8
121:14,23 122:11
122:20 123:3
125:4 126:4
127:20 129:2
132:25 136:11
139:13 144:5
146:7,10 150:23
151:11 152:10,18
154:7,14 155:7
156:12,25 157:8
158:13,24 159:7
159:13 160:10,21
162:6,19 163:20
164:19 165:2,7,25
167:11,22 168:24
169:22 170:8,21
172:5,9,16,23
173:6,16 174:9
178:4 180:13
184:9 186:12
187:12,24 188:23
189:5,21 192:7
194:14 195:21
196:8 198:22
199:4 201:13,22
202:9,21 203:5,13
203:23 204:12,24
205:10,24 206:17
207:5 208:21
209:4 211:12,23
216:3 218:19
219:12 220:8,18
221:7,17 223:8
224:7 225:6,19
227:3 235:18



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 432 of 465
Page 14
236:20 237:5,14
237:21 238:9,18
238:24 239:16,21
240:3,4 241:11,24
242:7,16 243:16
244:10,21 245:23
247:17 248:10,22
250:4 251:17,23
252:4,18,25 253:9
253:17,23 254:5
254:13,23 255:9
255:23 256:21
257:10 258:6,13
260:17,20,22
261:11,24 262:14
263:2,25 264:2,3
265:18 267:4,19
269:12,18 270:20
271:3,21 272:6
275:25 276:11,22
277:7,15,25
278:12,23 279:8
279:18 280:4,14
280:25 287:6,11
287:20 289:2,8,15
290:4,19 291:23
292:8,18 293:25
294:25 295:10
298:18 299:21
300:5,14 301:3,11
301:17 302:5,12
302:24 303:20
304:4,11 306:16
307:2,8,21 308:5
309:12,18 310:3
311:2,12 312:25
314:6,16 315:13
316:2,8 318:6,21
319:13,23 320:14
321:17 322:11
323:10,21 324:12
324:19 325:11,19
325:25 326:20,25
327:19 328:12,23
329:5,12,21 330:5
331:4,13 332:22
333:21 334:5,24
335:8,15,24 336:8
336:14,17,24
337:6,15,21 338:3
338:21 339:10,21
340:21 341:20
343:12 344:24
347:2 349:17
351:21 352:17
354:8,23 355:10
355:21 356:14,20
357:7 359:8,14
360:3 362:4,11
363:4,21 364:13
365:19 366:19
367:12 369:7,12
371:4 372:18
373:19 378:25
379:14,20 380:2,9
381:17,25 382:9
382:20 383:7
384:3 385:6 387:7
387:14 389:14,21
390:2,10 392:4
393:3,12,19,25
394:10 395:12,22
398:25 399:9
401:4 402:2,9
404:2,12 406:6,11
407:5,11 408:3,8
408:14,20 409:10
410:11 411:18
412:5,12,20 417:6
formally 71:6
former 134:15
fort 2:5,10
forward 351:7
353:8 368:7
forwarded 8:19
forwarding 390:24
found 73:5 218:15
325:15,21 349:2
350:4,13 382:16
foundation 6:6 9:2
12:3,25 13:14
14:5,13,21 15:17
15:25 16:8 18:4
18:19 19:13,20,25
22:23 24:3,14
26:2,10 27:13,25
29:10 32:5 33:2
33:17 37:6,15
39:7,14,20 40:4
40:13 41:16 42:22
43:3,18,25 45:2
45:17,23 46:9,20
47:23 48:4,9,16
48:22 49:5,12
51:4,9,17 52:6,19
56:4,13,19,25
57:10 58:4,9,15
58:19 60:7 61:23
63:12 64:13 67:3
68:10,16 69:20
70:4,9,15 71:14
74:6 75:16 76:15
77:3,23 78:19
79:4,11,18,24
81:2,7,13,24 82:6
82:14 83:21 84:20
87:13 89:14 92:8
92:17,25 93:12
96:25 97:19 98:16
98:25 99:18 100:2
100:13 109:5,10
109:16 113:14
116:12,23 117:8
121:15,23 122:11
123:3 125:4
127:20 129:2
132:25 136:11
139:13 144:5
146:10 150:23
151:11 152:10,18
154:7,14 155:7
156:12,25 157:8
158:13,24 159:7
159:13 160:10,21
162:6,19 163:21
164:19 165:2,7,25
167:11,22 168:24
169:22 170:8,21
172:5,9,16,23
173:6,16 174:9
180:13 184:9
187:12,24 188:23
189:5,21 192:7
195:21 196:8
198:22 199:4
201:13,22 202:9
202:21 203:5,13
203:23 204:12,24
205:10,24 206:17
207:5 208:21
209:4 211:12,23
216:3 219:12
220:9,18 221:7,17
223:8 224:7 225:6
225:19 227:3
235:18 236:20
237:5,15,21 238:9
238:18,25 239:16
239:22 240:4
241:11,24 242:7
242:16 243:17
244:10,21 245:23
247:17 248:11,22
250:4 251:17,23
252:5,18,25 253:9
253:17,23 254:5
254:13,23 255:9
255:24 256:21
257:10 258:6,13
260:22 261:11,24
262:14 263:2,25
265:18 267:4,19
269:12,19 270:3
270:20 271:3,21
272:6 275:25
276:11,22 277:7
277:15,25 278:12
278:24 279:8,18
280:4,14,25 287:6
287:11,20 289:2,8
289:15 290:4,19
291:23 292:8,18
293:25 294:25
295:10 298:19
299:21 300:5,14
301:3,11,17 302:5
302:12,24 303:20
304:4,11 306:16
307:2,8,21 308:6
309:12,18 310:3
311:3,12 312:25
314:6,16 315:13
316:2,8 318:6,21
319:13,24 320:14
321:18 322:11
323:10,21 324:13
324:19 325:11,19
325:25 326:20
327:2,19 328:13
328:24 329:5,12
329:21 330:6
331:5,13 332:22
333:21 334:5,24
335:8,15,24 336:8
336:14,17,24
337:7,15,22 338:3
339:11,21 340:21
343:12 344:24
347:2 349:7,18
351:21 354:8,23
355:10,21 356:14
356:20 357:7
359:8,15 360:3
362:4,11 363:4,21
364:13 365:19
366:19 367:12
369:7,13 371:4
372:18 373:19
378:25 379:14,20
380:2,9 381:18,25
382:9,20 383:7
384:4 385:6 387:7
388:16 389:14,21
390:3,10 392:4
393:3,12,19,25
394:10 395:12,22
398:25 399:9
401:4 402:2,10
404:2,12 406:6,12
407:6,12 408:3,8



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 433 of 465
Page 15
408:14,20 409:10
410:11 411:18
412:5,12,20
four 72:20 79:2
frankly 21:18
free 23:11 167:5
274:13
french 371:19
379:17
frequency 127:16
frequent 30:17
frequently 30:6
127:23
friday 353:6
friend 13:24 23:16
37:16,17 40:23
58:22 101:8 154:3
155:5 161:22
184:18 193:3
304:19 326:10
339:14 401:22
402:7
friendly 57:19
101:14 136:5
295:16
friends 13:19,20,21
13:23 14:7 22:24
23:2,17,25 30:22
30:22 57:22 59:3
107:22,25 116:10
116:10 121:17
135:15 138:11,15
154:11 163:24
305:11 339:8
351:6,13,18,24
352:12,14 376:24
408:6
friendship 101:10
front 15:22 24:23
131:17 149:11
168:15 171:9
209:16 213:20
214:24 264:2,2
275:2 312:18
316:18 317:4
330:15 361:7
fulfilled 384:13
full 28:6 73:22 74:3
75:2 86:11 250:14
fulltime 32:19
fully 210:12
functions 9:24
310:13
funded 371:20
funds 408:18
funeral 85:5
further 7:16 170:11
265:9 346:2
furthermore 82:9
future 286:7 413:9
G
g 2:13 4:1,6 5:1 6:1
7:1 8:1 9:1 10:1
11:1 12:1 13:1
14:1 15:1 16:1
17:1 18:1 19:1
20:1 21:1 22:1
23:1 24:1 25:1
26:1 27:1 28:1
29:1 30:1 31:1
32:1 33:1 34:1
35:1 36:1 37:1
38:1 39:1 40:1
41:1 42:1 43:1
44:1 45:1 46:1
47:1 48:1 49:1
50:1 51:1 52:1
53:1 54:1 55:1
56:1 57:1 58:1
59:1 60:1 61:1
62:1 63:1 64:1
65:1 66:1 67:1
68:1 69:1 70:1
71:1 72:1 73:1
74:1 75:1 76:1
77:1 78:1 79:1
80:1 81:1 82:1
83:1 84:1 85:1
86:1 87:1 88:1
89:1 90:1 91:1
92:1 93:1 94:1
95:1 96:1 97:1
98:1 99:1 100:1
101:1 102:1 103:1
104:1 105:1 106:1
107:1 108:1 109:1
110:1 111:1 112:1
113:1 114:1 115:1
116:1 117:1 118:1
119:1 120:1 121:1
122:1 123:1 124:1
125:1 126:1 127:1
128:1 129:1 130:1
131:1 132:1 133:1
134:1 135:1 136:1
137:1 138:1 139:1
140:1 141:1 142:1
143:1 144:1 145:1
146:1 147:1 148:1
149:1 150:1 151:1
152:1 153:1 154:1
155:1 156:1 157:1
158:1 159:1 160:1
161:1 162:1 163:1
164:1 165:1 166:1
167:1 168:1,6
169:1 170:1 171:1
172:1 173:1 174:1
175:1 176:1 177:1
178:1 179:1 180:1
181:1 182:1 183:1
184:1 185:1 186:1
187:1 188:1 189:1
190:1 191:1 192:1
193:1 194:1 195:1
196:1 197:1 198:1
199:1 200:1 201:1
202:1 203:1 204:1
205:1 206:1 207:1
208:1 209:1 210:1
211:1 212:1 213:1
214:1 215:1 216:1
217:1 218:1 219:1
220:1 221:1 222:1
223:1 224:1 225:1
226:1 227:1 228:1
229:1 230:1 231:1
232:1 233:1 234:1
235:1 236:1 237:1
238:1 239:1 240:1
241:1 242:1 243:1
244:1 245:1 246:1
247:1 248:1 249:1
250:1 251:1 252:1
253:1 254:1 255:1
256:1 257:1 258:1
259:1 260:1 261:1
262:1 263:1 264:1
265:1 266:1 267:1
268:1 269:1 270:1
271:1 272:1 273:1
274:1 275:1 276:1
277:1 278:1 279:1
280:1 281:1 282:1
283:1 284:1 285:1
286:1 287:1 288:1
289:1 290:1 291:1
292:1 293:1 294:1
295:1 296:1 297:1
298:1 299:1 300:1
301:1 302:1 303:1
304:1 305:1 306:1
307:1 308:1 309:1
310:1 311:1 312:1
313:1 314:1 315:1
316:1 317:1 318:1
319:1 320:1 321:1
322:1 323:1 324:1
325:1 326:1 327:1
328:1 329:1 330:1
331:1 332:1 333:1
334:1 335:1 336:1
337:1 338:1 339:1
340:1 341:1 342:1
343:1 344:1 345:1
346:1 347:1 348:1
349:1 350:1 351:1
352:1 353:1 354:1
355:1 356:1 357:1
358:1 359:1 360:1
361:1 362:1 363:1
364:1 365:1 366:1
367:1 368:1 369:1
370:1 371:1 372:1
373:1 374:1 375:1
376:1 377:1 378:1
379:1 380:1 381:1
382:1 383:1 384:1
385:1 386:1 387:1
388:1 389:1 390:1
391:1 392:1 393:1
394:1 395:1 396:1
397:1 398:1 399:1
400:1 401:1 402:1
403:1 404:1 405:1
406:1 407:1 408:1
409:1 410:1 411:1
412:1 413:1
gardener 50:22
247:4
gardeners 31:13
245:11 310:11
132:15
gathering 387:17
general 11:5,12
12:12 51:23 66:20
136:20,22 197:5
313:23 323:5
george 123:5
georgina 123:5
145:4,10
getting 77:10
181:11 219:22
246:4 349:13
391:17
ghislaine 1:8,13 3:5
3:6 120:17 127:5
156:18,21 157:14
210:10,24 349:3
372:20 389:7
405:18 414:6
416:6 417:9
giant 82:8 206:6
282:18
gift 113:5,7,9 191:8
191:25 192:2
286:25 287:2
343:10,16
gifts 113:12,16,19



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 434 of 465
Page 16
340:16,23 341:3
343:8,17,18
girl 68:23 69:8,11
69:13,16 92:20
97:15,21 167:8,13
167:17,20 221:4
221:14,21 222:4,7
223:5,6 225:2
236:18 262:12,19
262:24
girlfriend 91:12,14
91:17,20,23
101:11 295:5,12
363:19 364:4,11
365:5,7,10,14,17
366:8,12,22 367:8
367:15,18
girls 25:13 26:25
41:3,7 46:7,10,14
46:17 48:13,19
51:22 56:22 57:7
81:22 82:3 83:17
84:2,3,8,9,17
87:20 88:4,19
89:25 90:6 93:8
93:16,18,21,22
94:10,14,21 96:22
97:4 99:10,13,14
99:20,23 100:4,6
107:21 116:7,13
116:14,15 154:10
161:3,5 188:10
195:18 220:4
243:15,18 253:14
253:20 254:2,20
255:6,22 269:8,15
269:21 301:9
322:22 325:16
329:8,16,25
330:10 335:13
379:11,17,23
380:6,11,15 382:4
382:16,21 383:2
giuffre 1:5 3:6,22
3:24 4:2 7:10 14:9
85:9 151:20 158:3
234:11 254:10
259:22 265:9
266:15 319:18
give 5:2,15 14:16
15:15 19:8 27:23
35:20 45:21 48:14
48:19 49:3 57:25
60:13 61:7,23
74:15 77:21 78:2
87:10 103:12
113:9 143:5 153:3
160:22 162:16
191:21 192:21
220:14 224:19,22
224:23 226:15
237:2 262:18
288:9 291:2 297:7
303:17 315:7
325:8 340:23
352:5 371:22
374:8 386:12
410:12
given 19:16,22 22:7
22:11,16 55:20,24
89:19 92:4,21
113:12,16 204:17
211:24 219:10
226:17,19 251:9
257:6,13,18,22
262:23 285:24
286:13,25 291:5
321:15 325:5
356:12 370:9
385:17 416:8
417:5
giving 5:10 92:22
113:4,19 191:23
192:3,24 225:3
238:10 262:11
367:3 373:14
386:11
57:12,15 58:7
61:17 237:2
303:17,25 304:8
304:15
57:25
global 136:8
gloves 73:17
gm 34:6 120:17
122:17,17,22,24
123:4,7,23 124:8
124:16,16,16,17
124:17,18,20,21
124:21,22,25
125:7,11,23
127:10,18 128:12
129:20,24 131:7
132:14 145:3,9
152:3,8 209:15,19
266:24 345:14
346:16 352:21,21
356:3 398:6
399:11
345:17,17
346:4 348:23
351:4 369:4
399:13
34:12
gms 128:16
go 5:7 8:12 73:16
74:23 114:22
117:23 125:14,17
129:12 132:13
133:19 139:5,6
142:7 150:23
166:22 171:19
174:23 175:13
177:6 182:3
183:19 188:3
213:2,3 221:18
231:12,16 233:2
233:24 234:4
237:2 246:7
250:18 258:22
263:6 264:19
276:4 278:17
306:9 311:8 312:7
314:12 337:15
346:2 356:6
376:22 377:4
383:23 397:22
411:25 412:7
godparent 376:11
goes 139:10,24
369:18
going 4:12,17 11:4
11:10 19:25 20:11
23:4 65:12,16
74:12,22 83:5
93:4 102:13 111:7
111:11 114:5
117:23 118:13
119:16 120:11
121:4 124:14
125:15,20 129:14
129:16,16 130:4
131:9,17,18,19,23
132:5 133:14
139:22,22 144:13
144:16,22 148:15
148:19 149:15
151:16 157:17
158:4,15 165:10
165:12 175:21
179:12 205:3
207:18 229:23
259:9 262:16,21
263:10,11,18
264:18,22 265:8
265:24 266:6,10
274:7 286:4
291:19 292:4
295:17 308:6,22
309:2 312:13
318:17 319:15,17
319:18 327:5
334:9,13,17
335:12 338:12
345:4,10,14,15
346:3 348:17
350:23 351:23
353:11 356:2,4
359:23 365:12
367:2 368:3 373:2
386:17 397:25
412:18
good 4:12 31:24
128:7 158:18
184:16,17 244:22
246:11 247:6
372:6
goodness 230:7
230:19,21,22
231:2,3,4,7,8
government 325:15
325:21 407:23
408:18,24 409:6,8
409:13
201:9,18 202:4
202:11 203:16
204:2 210:5 273:2
273:6,13 348:21
349:15 353:8
361:6,17 391:7,10
391:16 405:14
354:13
grand 344:3,8,12
344:16,22 345:5
346:21,23 347:6
347:10,11
grandparents
191:9 244:6
group 267:25 389:4
guardian 390:25
391:18
guarding 293:22
guessing 297:9
guest 112:5
guilty 184:14
guise 247:21
guy 50:20 376:3
guys 36:7 76:20
182:19 316:12
375:22
326:6,7
326:24
H
h 4:6 168:6 414:10
haddon 2:16
half 78:6 174:15
190:14
halfway 25:8
131:25 321:4,8



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 435 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 436 of 465
Page 18
223:17,21 226:17
226:20 227:17,24
231:18,21 232:25
234:7 235:8
241:22 242:5,11
242:18 243:9,13
246:15 247:21
248:9,18,19,19,24
249:10,21 251:12
254:11,16,21
255:7,12 291:10
291:13,20 293:19
293:20,21,21
294:7 310:21
313:11,12 317:15
330:2,10 332:5
339:8 379:5
380:11,12,16
381:22,22 382:6
383:11 397:16
404:18
household 339:15
housekeepers
310:11
houses 11:22,23
12:6 66:19 67:9
81:20 136:17
397:15,20,23
husband 57:21
hyperion 387:23
hypothetical
240:20 241:2
hypothetically
286:3
hysterically 87:3
I
idea 13:3 23:19,21
29:23 37:7,10,19
37:25 38:4 41:5
41:17,23 42:16,19
42:23 46:12,16,21
46:25 47:4 49:18
57:4,11 58:16,20
59:2 65:25 67:13
68:17,20,25 69:5
71:15 79:12,20
99:20 106:14
114:3 121:16
127:22 147:7,12
147:14 152:20
159:14 162:7
166:4 189:7
194:20 257:17
260:18 261:25
278:2 305:21
307:4 318:7
329:13 331:18
334:8 337:9
347:23 350:6,20
350:21 351:22
365:6,20,22 369:8
369:20 380:24
381:6,9 388:7
392:5,11 395:7
397:12,18,21
406:7,13 408:9
identification 24:21
34:2 71:18 109:21
113:22 117:20
133:7 143:11
147:24 209:14
259:12 263:9
312:16 345:13
348:20 350:25
361:3 363:13
365:24 367:23
384:22 390:22
392:13 398:4
405:5
identified 259:25
284:19 346:11
348:22
identifies 284:25
identify 5:17 142:9
142:11,12,13,14
148:2 150:7
213:17 266:3
275:13,14 386:22
identifying 217:3
identity 386:10
ill 374:9 375:13
377:5
illegal 21:13 389:24
390:8,12
im 4:12 6:14,22
7:11,23 9:13,14
9:19 10:18 13:22
14:24,25 15:6,6
16:3,4 17:11
19:25 20:11 22:3
23:2,2,4,21 24:7
29:2,4,20 32:11
32:18 33:13 34:3
34:16 37:23 49:14
51:19,23 52:3,23
52:25 53:2,7,8,12
53:17,20,20 54:8
54:17,18 61:6
62:3,8 65:15,23
73:6 74:22,23
82:15,16,21 83:5
84:24 85:21 86:4
88:2,2 90:9,10
94:2,3,6 95:21
96:4,9 97:9
102:13 109:22
114:5 117:16
118:13 119:16
120:2,7,11 122:14
123:19 124:5,5,10
125:5,5 126:19,20
126:20,22 129:16
129:18,18 131:17
131:20 132:16
133:14 136:4,15
137:9,24,25
139:20,25 140:5,8
144:13,17,22
145:7 147:6
148:19 149:15,22
150:5,24 151:16
152:13 154:25
157:17 158:4,15
160:24 161:2,19
165:10 168:16
171:11,16 173:19
173:19,20 174:20
174:20 175:10
177:18 178:2,25
179:2,2,6,7
180:16 181:11
182:12 183:17
184:15 192:20,20
196:10,15,21
197:12,20 198:8
199:6,9,14,15,17
200:4,10,19,22
203:14,17 204:13
209:8 211:13
212:16 214:2,3,16
216:20 219:16
220:21,23 222:16
222:19 223:17
224:16,17,24,25
226:12 230:12
232:5 234:13
235:6,20 237:17
240:23 242:9
244:17 245:14
250:9,10 253:12
259:9,21 263:10
263:11,18 264:25
265:2,5,8,24
266:6,10,12 268:6
272:24 274:7,21
275:13 276:2,12
276:15,23 277:20
280:5 281:3,8,14
281:20 284:3,23
284:23 285:6
286:20 294:19
296:12 297:25
299:3 302:14,25
303:4,11,14 307:3
307:9 308:6,22
309:2 310:7
312:12,21 313:11
315:18 316:13
318:22 319:7,15
319:18 320:3,3,19
323:24 325:23
329:14,24 330:14
334:9,13 335:9
338:12 340:24
341:18 342:18,25
343:14,19 345:10
345:14 346:6
347:15,16 348:12
348:17 350:17,20
350:23 353:12
354:17 355:14,15
356:2,21 358:3,4
358:8,24 361:17
363:7,8 365:8
366:13 368:3,20
371:19 372:13
373:2,25 377:9
380:12 382:14
383:13 384:18,23
386:9,15 396:22
397:25 398:14
403:16 405:3,6
409:17
images 188:10
imagine 283:13,19
389:22
implication 95:12
important 5:6 6:20
78:4 216:13
importantly 12:5
impossible 26:21
123:14 126:22
164:8 193:8
213:17 226:18,21
234:8 273:20
improbable 148:18
inaccurate 357:18
358:14
inappropriate
53:18 181:23
182:21 183:5,9
190:25 193:4
194:11 197:6
206:7 207:21
225:11 226:14
250:8,10
inappropriately
207:20
inappropriateness



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 437 of 465
Page 19
191:3
include 69:15
included 31:9
includes 7:14
including 15:13
52:14 108:20
235:9 380:13
income 102:11,15
incoming 149:4
inconsistency 215:7
216:13
inconsistent 217:12
incorrect 35:23
36:3 225:12
226:14 328:11
incorrectly 129:17
increased 102:6
indefinitely 374:11
independent 74:24
155:24 263:22
281:15,21
indicate 153:5
160:18 378:8
indicated 209:18
indicates 282:24
indicating 73:9
indication 130:21
indirect 296:8
indirectly 394:6
individual 22:16
40:20 50:4,5,10
126:16 128:13
142:17 151:8
190:15 193:23
194:4 210:8
302:13 314:14
318:16 326:17
376:12 383:24
401:24 402:6
individuals 23:3
31:7 49:24 89:8
121:20 122:2
126:13 127:7
128:7 142:10
145:16,23 154:9
192:5 193:6
209:22 311:9
312:3 314:4
315:10 331:21
333:2,10 353:9
383:13 411:6
infer 204:18 205:18
inference 232:19
info 398:12
inform 344:21
information 6:8
7:13 20:9,14 25:4
103:2 199:23
200:6 265:21
281:7,12 282:9,23
283:3,14,15,20
313:20 314:3,13
314:14,19 315:3
315:10 316:5,23
318:18 331:21
332:14 333:10
335:5 350:2,2,11
354:20 356:17
360:7,17 389:18
407:3,9
informational
354:11
informed 393:16
infrequently 155:3
164:8 186:18
246:7
inhibit 5:14
initial 28:7 125:11
206:4
initially 34:10
initials 120:16
123:7 127:9,10,18
130:6,8,23 152:8
266:24
initiative 136:9
input 318:17
319:21 320:24
321:16 326:16
inputting 320:20
inserted 368:23
inside 189:25
218:21 288:24
293:23
insignificant 341:2
insofar 394:2
instruct 19:25
20:11,16 21:19
58:6 61:16 65:2
92:25 102:13
274:8 308:6,23
309:3
instructed 58:10
62:10 65:7 87:4
202:11 260:19
281:18 335:20
413:5
instructing 22:3
52:23 62:3 199:7
199:9 281:3,8
284:4
instruction 55:3
64:4,25 308:12,16
394:21
instructions 257:6
257:13,17 262:12
262:18,23 281:24
instructor 60:16
247:5 248:8,17
instructors 50:23
245:11 246:19
247:13 249:18
250:11
intend 372:4,9
interact 402:3
interacted 179:18
182:2 384:16,19
interacting 45:12
401:21,22
interaction 20:10
145:22 219:5
292:5 308:4
interactions 21:23
intercourse 52:17
53:6,8
interest 31:4 199:9
200:3 356:15
interested 197:21
220:23 370:21
392:24 393:5
interject 10:15,20
international
275:22 276:6,17
277:3,21 278:7,19
279:4,13,23 280:9
interpose 45:22
interpret 69:7
interrupt 357:12
interrupting 23:5
181:18
interstate 275:21
276:5,16 277:3,21
278:6,18 279:3,12
279:22 280:9
interview 59:17,22
221:12,15,21
222:7,10,15,24
246:22
interviewed 222:12
222:12 248:5
384:8
interviewing 59:21
intimate 295:18
introduce 17:19
18:11 33:21 63:9
97:16,22 106:25
107:14,20 108:3
108:11 270:16
introduced 56:8
86:12 101:7,8
107:4,23 309:23
introducing 309:10
309:16
introduction 63:16
309:20
investigation 24:12
24:17 168:19
169:15 170:3,15
171:6 186:3 195:3
408:10
invitation 13:21
invite 13:11,16 14:3
14:9,17 15:19
16:5
invited 13:22 14:15
14:25 15:7,14,21
147:8 249:7
inviting 14:7 49:2
involve 21:17 286:6
308:21
involved 40:16
42:18 46:6,13
52:22 61:14 64:16
64:19 65:2 195:3
210:18 228:6
231:10 313:4,8
374:13,22 390:7
involves 21:21 62:2
involving 49:10
329:18
irregularly 163:14
island 115:17,18,24
116:2,8,13 134:2
134:4,7,12,13,18
135:7 137:6
230:21 231:2,3,4
231:8 301:15,21
301:23 380:13,16
islands 115:13
125:21,25 126:14
127:4,13 351:10
388:15
isnt 108:8 166:15
197:25 215:3
363:2 391:17
397:3
israel 409:15
israeli 409:8,13
issue 4:25 65:2
117:10 121:2
173:4 184:21
201:8,17 202:3,11
273:6,12 351:6
issued 24:11 203:15
273:2 274:22,25
361:11,12 385:4,9
385:23 386:2
399:3,22
issues 184:11,22
298:25 376:13,15
issuing 357:23



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 438 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 439 of 465
Page 21
396:25 397:2,5,11
397:13 404:10
405:10 407:2,22
408:5,11,16 409:7
409:16,20,22
410:3,8,22 411:14
412:3,22
jeffreys 13:12,17
14:3 37:16,17
38:18 40:24 47:3
57:7 60:5 79:15
84:18 98:14,22
99:15,24 100:10
105:3,4,6 113:17
115:12,18 121:19
127:12 131:11
134:2,22 135:22
137:6,8,9,12
145:22 157:6,10
190:8,16 216:11
217:24 224:18
243:13 245:18
252:7 253:11
255:13 289:23
298:17 301:15
326:10 328:5
329:9,17 333:6
336:12 368:25
374:16 376:4
384:17 397:15
jege 388:9,10
jersey 118:23
268:25 271:9
129:23
131:14
jet 138:20
jfk 264:19
job 4:23 12:4,21
15:11 28:24 31:9
31:16 32:8 59:16
60:18,22,23 66:23
67:8,9 147:9
154:19 245:16,25
246:3,23 247:4
311:6 314:21,24
315:2 383:8 412:6
jobs 102:9 383:10
383:17 384:8
59:7,8,10
59:21,24 60:10
61:9,16,21 62:6,9
62:15 63:2,9,13
112:25 289:25
290:17,21 292:24
307:6,10,12,16,17
308:18 309:16,20
309:23 310:18,22
311:5,17 312:11
321:25
62:16
321:5,9 322:8
116:21 218:9
218:10,24 391:9
391:13
joint 200:2 299:7
299:10
260:8,9,13,15
261:3,3,5,8,14,17
261:21
journal 327:14,16
71:22,23 73:3
judge 7:6 74:19
jump 11:15
jumping 86:25
june 34:7,11 345:17
347:14 356:5
jury 285:13,17
K
k 345:22 390:14
keep 11:17 33:5
181:14 247:18
266:12 313:19
314:18 315:3
318:10 334:20
373:3 393:15
keeping 314:23
318:23 322:7
47:15 49:8
49:17 56:21 57:4
57:6 255:3,19
328:22,25 329:2
378:11,21 395:16
396:5,9,14 411:15
411:21 412:9,17
124:18,18,20
124:21
kept 70:2 314:2
316:15
266:22
kids 13:21,22,23
107:25 121:18
kind 71:3 103:3
119:20 229:19
255:14 277:13
287:23 311:15
316:15 342:16
381:15 404:19
kinds 73:4 256:7
kingdom 273:15
362:14
knew 66:10,12
86:22 89:18 107:8
232:9 314:4 333:2
359:11,19 361:23
362:6,22,24 363:5
388:6
know 8:12 24:4
25:12 28:13,13,15
28:19 33:5,7,10
33:23 36:10,24
37:8 40:19 41:11
41:19 42:2 43:6
43:16,19 44:8,16
44:18,19,20 46:4
47:15 48:5,17
52:10 55:9 56:6
57:12,20 58:23
59:2,24 63:15,17
63:20 64:14,24
66:5,7 69:11
71:23 75:7,12
76:9,18 77:4,5
79:7 80:14 89:23
89:24 90:19,23
94:2 95:11 96:5
98:7,9 100:16
101:5,19,24
103:12,15 105:14
105:15,17 106:12
106:15 107:7,10
107:12,13,16,18
108:16 109:2,7,11
111:16 113:15
114:4,9,13,15,17
114:19,20 115:20
115:23 119:6
122:12,13,13,21
122:22 123:8
131:14 134:18
136:12,13,15
137:11,14,16
138:16 140:16
141:5,6,11 142:21
143:17 149:20
151:5,14 153:12
153:14,18,19
154:3,8,15 155:4
155:8,9,10,10,11
155:15 156:5,13
158:8,10,14,25
159:3,8 160:5,11
160:13,13,15,24
161:10,14,19,24
162:2 163:10
164:2,3,17,20,21
165:3,9,16,18,21
166:6,10,14 167:7
167:12,19,23
171:9,10,19,20,22
172:12,19,24,25
173:2,3,7,10,24
174:11,12,12,14
174:24,24 175:8
176:5,22 177:3,4
177:6 182:13,17
182:17,25 183:3
183:19,20,23
186:20 189:2,6,12
191:24 192:17
196:14,18 197:17
199:20 200:17
204:14 205:25
206:2,3 207:23
208:22 213:21
214:25 215:3
216:5,21 217:2,5
217:14,15 218:3
218:13 219:6
220:24 222:9
223:18 227:21
229:9 230:22
231:2,5,6,7,23
232:12,17,20
233:12,18,20
236:22 237:9,10
237:22 238:4
239:4 240:14
241:14,15,17
244:15 248:5
249:8,18 252:8,13
252:13,21 253:5
254:6,7 255:16
257:20,21,23
258:20 259:16
260:5,9,10,12,14
260:16,23,24,24
261:8,13,16 262:4
262:16,20,22
263:4,5,7 267:20
268:21 270:18,22
270:24 271:7,7,9
271:12,19,22,22
272:13,25 273:23
278:13 280:23
281:4 282:12,14
282:15 283:7,10
283:12,18,21
285:8,24 286:11
286:14,21 287:25
288:6 289:19,20
289:21 290:8,21
292:11 294:18
297:3 300:21,23
301:5,19 302:15
304:5,7,18,23
306:11,23,24
307:3 311:19
313:2,18 314:25
316:9,11 317:21




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 440 of 465
Page 22
319:5,11 321:13
322:12,21,23,23
322:25 323:2,4,5
323:7 324:9 326:7
326:23 327:23
328:6,16 330:17
332:2,8,23 334:7
338:5,10 344:9,11
344:13 345:7,8,8
347:3,6,8,8 348:2
348:9 349:8 352:4
352:7,8,10,14
354:14 355:3,6
361:9 365:4,21
368:8,10 369:14
370:18,21 373:4
374:15 376:10
377:13,18,25,25
378:14,15 379:22
380:4,19,25
381:21,23 382:2
384:12 385:14,18
385:20,23 389:2,6
389:18,23 391:13
393:4 395:15,18
395:23 397:4,19
398:15 399:10,14
399:20,24 401:12
405:19 407:22
408:5 409:12
410:21 412:17,21
knowing 99:12
100:4 163:23
170:18 171:4,5
173:13 344:25
347:11
knowledge 52:21
88:15 89:2,15,22
119:4 126:9
134:23 168:18
174:18 178:9,16
178:20 179:22,24
180:22 182:4
184:10 188:24
238:20 242:24
252:11,12 256:22
268:4 269:24
280:7 281:16,22
282:6 304:17
305:14,15,18
321:21 325:22
326:2,21 327:4
329:8,16,25 330:9
335:18 339:12
350:19 378:10
389:24 395:13
398:20 402:20,23
406:22 407:13
408:4,15 409:4,11
409:14
known 38:10
106:17 261:17,21
294:20
knows 36:6 119:12
119:13 196:20
272:3 363:5,8
L
l 1:5 2:9 4:6,6,6
168:6,6,6
label 72:23 141:9
319:18
labeled 34:5
labled 367:25
lake 2:14
land 371:14 377:19
378:2
landed 377:24
landscapes 193:12
194:17
language 94:24
95:3,22 96:2
179:22 209:8
210:5 347:17
lap 290:11
large 28:24
largely 187:18
412:13,14,16
larger 148:23
47:2
las 2:4
late 376:12
latest 391:17
lauderdale 2:10
lauderdatle 2:5
laundry 70:6,11,16
70:21 73:20,21,21
74:3
laura 2:19 4:4
law 1:15 103:6
207:21
lawsuit 20:5 102:20
102:22 361:20
362:2
lawsuits 184:6
lawyer 62:13 65:7
120:22 199:8,24
200:10 202:10
203:16,16 205:13
274:11 275:15,18
281:8,13,18
347:24 360:15,24
362:18 375:23
394:6,13,18 406:9
lawyers 199:16,25
200:12 273:10,11
274:16 281:22,25
282:5 283:21
284:3 286:16,22
345:23 362:21
395:4 398:18
413:16
lay 6:20 86:13
laying 29:25
layout 12:17
lead 180:24 217:23
218:10
leaders 210:16
leading 156:6
leads 180:6
leak 349:25 350:10
406:18
leakage 349:4,22
349:23
leaked 349:7,24
350:18
leaking 349:5,9,15
349:19 406:10
learn 186:6 325:14
396:4
learned 76:19
199:22 281:7,13
335:5
leather 69:17
leave 7:20 11:11
43:15 50:16
133:22 138:20
165:23 374:11
leaving 73:23 165:4
lecture 100:21
led 216:10 218:3,13
220:5 221:4,12,15
221:22
left 50:20,21 106:13
139:5 142:8,12,13
142:18 158:11,16
165:12,14 166:24
185:9 219:19
227:14 373:5
376:22 377:4,6
410:15
lefthand 234:22
leg 140:6
legal 1:24 49:13
250:21 254:18
343:22 353:20
361:19 362:5,8,12
362:13,17 363:2
363:11 368:22,23
legs 86:20
lehrman 2:9
length 227:12
229:7
117:6,13 314:11
379:5 380:22,22
381:2,21
1:19 3:15
403:9,24 404:6
416:11
lessened 10:12,22
lesser 297:5,16
lessons 167:5
letter 34:16 346:7
346:14,15 353:15
368:13
letters 118:21
level 123:4
lewis 124:15,15,16
364:8,10
lexington 1:16 3:11
lfbep 132:7
liar 76:8 105:17
174:12 175:4,13
175:15 176:8
177:3,6,7 179:25
182:5,17 183:4,20
196:5,10,24
239:13,25 240:13
240:14,17 241:7
241:16 275:4
361:22,24 362:7
362:25 400:3,5,7
400:9,12,14,15,24
license 104:11
lie 33:7,10 134:14
135:9 171:24
174:13 175:16,17
178:17 180:2
182:18 183:14,21
200:23 202:17,24
203:9,18,21 204:8
206:7 207:2,10,17
208:25 211:9,13
211:20 212:12,18
212:22,23 213:8
214:18,20 215:6
215:15,16,20
216:6,13,14,22,23
217:9,19,21
226:17 227:10
228:9 229:4
231:20 233:12
235:3,5,8,15,15
236:17,25 241:21
242:3,10,14 243:8
243:14,14 244:7
244:12,17 245:19
251:13,19,25
254:9 256:17
257:5,12 400:10




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 441 of 465
Page 23
lied 18:25 19:3 76:9
87:25 175:6 177:4
177:4 202:13,15
228:19,20,20
241:14,17 257:23
lies 30:5 31:3 35:17
53:17 69:22 82:8
89:20 90:4,9,10
90:12,14,25
104:19 107:3,3,6
107:15,15 108:6
135:5,6 171:21
176:12 180:3,9
182:8,24 183:5
197:3,5,6,11,18
198:20 199:2,19
200:16,21 201:11
201:20 202:7
204:3,5,15,16
205:6,15,16,17
207:7 209:10
210:20,25 212:7
212:13 213:21
227:6,7 228:5
229:24 230:4,17
233:2 240:8
241:14 273:16,22
298:23,24 299:19
300:25 302:17,17
303:14 400:16
life 96:10,11,12
245:18 305:6
315:22
lifetime 390:8
407:25
liked 91:22
limit 96:15
limited 89:16 90:22
91:5 96:12 184:20
243:23 369:17
line 35:4 65:19 86:7
118:18 123:20
125:16,18 129:14
145:2,2 150:13,15
160:7 209:21
345:20 348:25
350:3 356:6
363:17 418:3
lines 85:14,23
120:3 124:13
262:7 267:24
302:21 336:15
337:20
list 107:6 125:22
129:19 229:23
322:18,22,24
325:16 326:17
331:20 333:10,18
333:25 382:4,12
382:12,15 383:2
384:15
listed 128:23
261:19 323:8,18
324:2,6,10 326:14
383:10 395:9,16
listen 177:9 202:2
253:3
lists 123:22 332:13
litigation 20:13,20
20:22 371:2,6
386:23
little 34:17 91:9
102:6 115:13
118:12 119:18
185:3,6 234:17
265:9 297:18
346:7 393:14,14
live 76:13 155:19
268:22 372:4,9
lived 66:11 397:19
lives 66:5,7 156:7
271:10 306:11
living 8:6 155:23
372:11
llc 388:22
llp 2:3
loan 104:2,3 339:19
339:23,23 340:2
342:24,25 343:2
loans 104:2 340:3,6
340:11,12
located 236:13
331:3
location 17:25
locations 138:19
log 132:4 133:22
266:9 313:19
logs 117:19 118:9
118:25 122:24
124:8,12 127:17
127:22 128:20
141:17 144:14
147:13 266:7
377:16,22 409:18
414:18
london 97:16,22
98:2 108:4,5,12
108:15,21 111:5,9
111:24 112:6
114:2,7 132:9,9
141:22,22 205:14
231:18,21 232:3
232:23 233:19
234:7,10,16
235:12 236:9,14
long 10:7 106:17,18
106:20,21 107:6
195:14 245:13
271:14 305:21
315:14 319:7
341:6,14 342:11
347:15 386:4,16
390:14
longer 255:12
283:18 327:15
look 34:10 38:6
42:24 43:4,8,11
71:21 109:24
114:6 118:9
124:13 125:15,19
127:3,21,24
132:12,13 133:19
142:20,24 143:25
147:13 149:11
150:6 165:11
169:6,7 198:10
259:23 262:7
263:11 266:18
267:21,23 268:7
285:9 310:15
312:17 315:21
317:19 322:17,18
322:20 368:3,11
377:20 378:4,13
385:2 390:25
392:14
looked 38:8 43:7,20
110:2 113:6
213:10 383:16
looking 73:10
110:25 120:8
124:12,24 132:4
141:17 148:13
151:2 234:12,13
248:15,15 310:20
356:21 377:15
378:7
looks 72:14 129:21
146:12,17,18
150:15,18 153:9
234:23 266:8,21
267:9 306:3
368:18
124:17
los 66:13
lot 42:12 94:7 128:6
343:19 365:11
367:13
lots 246:2 288:7
331:24
love 158:19 316:11
loved 366:13
loyal 184:15
99:15,19 116:21
158:17,21,25
159:3,9,10 166:25
167:7 379:22
380:5,10,14
ludicrous 235:7
lure 183:11
lying 53:15 90:7
135:4 183:24
200:18 204:7,18
204:20 205:7,19
205:20 206:9
302:21
M
m 1:18 3:10 4:6
34:12 150:15
168:5,6 373:10
413:19,20
madison 264:12
magazine 191:2
244:3
magazines 192:14
magna 1:24
mail 7:24 8:19
350:16 353:8
maine 132:10
141:22
mainstream 191:2
192:14 244:3
maintain 184:12
257:6,13 258:17
making 9:19 44:9
54:18 180:18,20
195:18 198:20
199:2,19 222:15
359:23 362:7
367:9 392:25
393:16,22 405:24
411:5,7
male 129:22 223:20
246:16 249:11
man 31:25 246:9,12
324:25 386:5,6
manage 376:16
managed 319:9
mandated 129:6
212:2
mandatory 247:8
mangled 221:24
manifestly 207:16
manner 207:22
mansion 79:15
80:18,20,23 187:9
300:12
mantel 191:10
244:6,6




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 442 of 465
Page 24
mar 131:25
maralago 16:17
17:5,7,9 35:12
36:15,19 206:10
206:12,14 207:3
208:19 213:6,12
213:13,14,15,25
214:18
march 131:25
132:2 139:23,23
139:25 140:2
144:17 353:6
40:20
40:22 41:14,18,20
41:25 42:14,17
43:5 44:16,22
45:6,9,11,15,20
46:3 47:10 87:5
255:4,19 396:16
396:18
marham 124:19
mark 73:5 118:9
133:4 143:3
147:25 179:14
209:16 259:9
312:13 334:17
345:10 348:17
350:23 360:25
367:21 390:19
392:20,20 397:25
marked 24:21
33:25 34:4 71:18
109:20,22 113:21
117:20 133:6
142:21 143:10
147:24 168:15
209:13 259:11,20
259:21 263:9
266:8 312:16
345:12 348:19
350:24 361:2
363:12 365:23
367:22 384:21,23
390:21 392:12
398:3 405:4,7
marking 71:20
405:3
145:3,10
massage 14:16
15:13,15 18:13
19:9,16,23 21:8
22:7,11,16 25:9
25:10,11 27:23
31:17,20,21,23,24
32:7,10,11 33:19
49:3 50:23,25
51:11,13,19,24
52:7,12 53:2 58:2
60:17 61:9,17
68:24 69:15 75:13
75:19,22 78:17,21
82:18,20 86:17
92:5,6,12,21,23
97:17,23 98:3,23
99:4 100:11,19,20
100:22 101:2
163:4,18 215:25
218:12,14 219:10
219:10,22,23
220:2,15,15 221:5
221:23 222:22
223:2,6 224:2,3
224:12,15,19,22
224:23 225:4,11
226:15 229:14,17
237:2 246:9,10,17
269:10,17,23
279:6,15,25
280:11,16 300:10
303:18 304:2,9,16
319:20 320:23
321:3 322:18
323:19 324:3,10
324:21,25 325:4,9
325:16
massaged 61:5
massages 27:11,18
31:7 48:14,19
60:12 66:25 68:14
68:19 77:21 78:3
81:22 82:4 83:11
83:19 87:10 92:3
93:9 98:14 99:16
140:25 141:3
153:20 154:12
162:16,24 180:10
183:11 222:13
237:8 245:21
246:4 253:15,21
254:3,21 255:7
307:11,16,18
308:2,17,21
326:15 329:18
massaging 67:7
masseuse 14:15,23
14:25 15:5,10,13
15:20,22 16:10
32:2,24 33:4,15
33:19 35:3 68:12
75:6,8 76:25 77:5
82:19 223:20
224:15,21 225:8
225:10 226:12,13
250:7,16,21 251:3
251:11 254:17
279:21 305:13
307:6,15,25
324:16,22 326:11
326:13 384:11
masseuses 53:21
55:6 67:10 220:20
220:25 222:13
223:16 225:16
250:24 323:8,18
324:2,5
masturbate 86:21
masturbating
52:16
matches 118:20
material 370:16
materials 12:18
matter 3:5 6:13
20:4,20 24:12,16
24:18 28:8 34:5
53:14 214:7
285:19
maxwell 1:8,14 3:5
3:7,18 4:1,5 5:1
5:22 6:1 7:1,15
8:1,23 9:1 10:1
11:1 12:1 13:1
14:1 15:1 16:1
17:1 18:1 19:1
20:1 21:1 22:1
23:1 24:1,20 25:1
25:3 26:1 27:1
28:1 29:1 30:1
31:1 32:1 33:1,25
34:1,4 35:1 36:1
37:1,3 38:1 39:1
40:1 41:1 42:1
43:1 44:1 45:1
46:1 47:1 48:1
49:1 50:1 51:1
52:1 53:1 54:1
55:1,5 56:1 57:1
58:1 59:1,6 60:1
61:1 62:1 63:1
64:1 65:1 66:1
67:1 68:1,4 69:1
70:1 71:1,17,19
71:20 72:1 73:1
73:19 74:1 75:1
76:1 77:1 78:1
79:1 80:1 81:1
82:1 83:1,6 84:1
85:1 86:1 87:1
88:1 89:1 90:1
91:1 92:1 93:1
94:1 95:1 96:1
97:1 98:1 99:1
100:1 101:1 102:1
103:1 104:1 105:1
106:1 107:1 108:1
109:1,20,23 110:1
111:1 112:1 113:1
113:21 114:1
115:1 116:1 117:1
117:19 118:1,7
119:1 120:1,17
121:1 122:1 123:1
124:1 125:1 126:1
127:1,6 128:1
129:1 130:1 131:1
132:1 133:1,4,6
134:1 135:1 136:1
137:1 138:1 139:1
140:1 141:1 142:1
143:1,10 144:1
145:1 146:1 147:1
147:23 148:1
149:1 150:1,13
151:1 152:1 153:1
154:1 155:1 156:1
157:1 158:1 159:1
159:24 160:1,6
161:1 162:1 163:1
164:1 165:1 166:1
167:1 168:1,13
169:1 170:1 171:1
172:1 173:1 174:1
175:1 176:1 177:1
178:1 179:1,17
180:1 181:1 182:1
183:1 184:1 185:1
186:1 187:1 188:1
189:1 190:1 191:1
192:1 193:1 194:1
195:1 196:1 197:1
198:1 199:1 200:1
201:1 202:1 203:1
204:1 205:1 206:1
207:1,19 208:1,18
209:1,13 210:1,4
210:10 211:1,2
212:1 213:1 214:1
215:1 216:1 217:1
218:1 219:1 220:1
221:1 222:1 223:1
224:1 225:1 226:1
227:1 228:1 229:1
230:1 231:1 232:1
233:1 234:1,13
235:1 236:1 237:1
238:1 239:1 240:1
241:1 242:1 243:1
244:1 245:1 246:1
247:1 248:1 249:1
250:1 251:1 252:1
253:1 254:1 255:1



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 443 of 465
Page 25
256:1,17 257:1
258:1 259:1,11
260:1,20 261:1
262:1 263:1,8
264:1 265:1 266:1
267:1 268:1 269:1
270:1 271:1 272:1
273:1 274:1 275:1
276:1 277:1 278:1
279:1 280:1 281:1
282:1 283:1 284:1
285:1 286:1 287:1
288:1 289:1 290:1
291:1 292:1 293:1
294:1,17 295:1
296:1 297:1 298:1
299:1 300:1 301:1
302:1 303:1 304:1
305:1 306:1 307:1
308:1 309:1 310:1
311:1 312:1,14,15
313:1 314:1 315:1
316:1 317:1 318:1
319:1 320:1 321:1
322:1 323:1 324:1
325:1 326:1 327:1
327:13 328:1
329:1 330:1 331:1
332:1 333:1 334:1
335:1 336:1 337:1
338:1 339:1 340:1
341:1 342:1 343:1
344:1 345:1,11,12
346:1 347:1 348:1
348:17,19 349:1
350:1,24 351:1
352:1,19 353:1,7
354:1 355:1 356:1
357:1 358:1 359:1
360:1,25 361:1,2
362:1 363:1,12
364:1 365:1,23
366:1,2 367:1,21
367:22 368:1
369:1 370:1 371:1
372:1,20 373:1,11
374:1 375:1 376:1
377:1 378:1 379:1
380:1 381:1 382:1
383:1 384:1,21,24
385:1 386:1 387:1
388:1 389:1,7
390:1,19,21 391:1
392:1,12 393:1
394:1 395:1 396:1
397:1,25 398:1,3
399:1 400:1 401:1
402:1 403:1 404:1
405:1,3,4,7 406:1
407:1 408:1 409:1
410:1 411:1 412:1
413:1 414:6,12
415:2 416:6 417:9
maxwells 73:19
210:24 309:5
mccawlely 358:18
mccawley 2:5 3:12
3:19,20 4:11 5:19
6:11,16,25 7:18
10:18 11:14 20:16
21:3,21 22:5
23:13 35:6 49:14
54:17 65:15,18
67:20 72:22,25
74:9,12,18,22
87:16 88:11,18,23
89:3 102:17,21
103:8 110:11,13
110:16,22 119:9
120:6 126:11
128:5 133:10,13
133:19 145:7
149:24 166:18
168:9 177:16
178:10 179:10
180:16 181:4,11
181:16 199:11
207:18 208:10
240:21 264:25
266:14 268:6
309:4 327:5
334:16 353:3
357:9,12 358:3,11
358:23 359:2
363:7,24 373:2
386:9,14,20 413:2
414:7
meal 136:24 137:3
137:5,7,9
mean 9:6,7 32:14
41:8 43:6 47:11
48:24 49:22 52:10
57:17 70:5 91:14
92:21 97:4,5
114:18 118:21
128:17,23 138:10
162:20 170:9,22
182:7 185:7
190:13 222:9
270:24 272:13
274:24 277:10
287:25 292:12
295:2,22 298:14
311:13 337:25
349:24 391:25
401:5 404:3 406:2
meaning 71:2
83:17 94:21
116:15 118:22,22
255:19 276:6,7,16
276:17 279:13
296:8 297:17
374:25
means 77:4 210:9
416:17
meant 32:14 86:23
392:7 406:14
mechanism 314:2
medical 80:4
medications 5:13
meet 16:5,12 18:2
32:21,22 33:21
35:12 37:4 40:22
45:5 47:17,19
59:8,13 97:15,21
101:3 111:25
146:19 218:24
219:21 222:21,25
223:4,22 247:9,20
262:12,19,23
270:9,13 273:21
303:11 304:25
411:16 412:18
meeting 16:15,16
16:19 17:2 19:3
33:24 36:14,18
40:24 206:12
213:6 214:9,17,19
271:8 300:18,20
306:22
meetings 66:22
member 17:5
389:11 402:7
members 382:11
memorized 269:3
memory 36:9,25
40:7 60:9 80:15
97:13 187:16
231:16 265:22
268:15,15,16
361:9
men 27:17 191:14
menninger 2:19 4:4
72:21 110:14
143:7 159:21
223:13
mental 241:3
mentioned 132:22
255:2 262:5
316:23 336:3
395:15
meredith 2:6 3:20
merely 360:9
message 147:23
148:3 149:6,7,7,8
149:10,12,20
150:17,20 151:2,8
151:9,25 152:2,6
152:14,16,24
153:3,4,6,24
154:2,5 155:8,11
156:17,18,22
157:3,4 158:6,11
158:17,17,18,22
160:3,12,14
161:12,16,18
162:4,8 163:16,22
164:4,5,21 165:4
165:9,13,15
166:23 349:3
391:5,9,15 414:21
messages 149:4
150:11,25 151:6
154:10,17,21
155:2 160:17
161:3 162:10
163:2,6 164:2
165:23 166:3
298:4,6
met 16:24 17:21
32:16 33:13 34:25
37:7,9,11,13,24
38:2,5,7,13,16
39:22 41:20 42:25
43:5 58:13,23
59:15 63:14,14
97:25 106:22
107:10,12,16,18
108:2 206:9,14
208:19 213:11
227:13 249:6
270:15,17,25
272:8 280:22
281:5,17,23
282:13 283:5,11
283:24 284:13,20
285:2,14,21
294:19 302:22
305:3 306:13,18
309:23 311:5
321:24 382:5
383:2,25 384:7
411:20
mexico 134:20
189:19 190:17
248:19 411:16,21
411:25 412:7,18
mid 295:14 403:20
403:22 404:4
middle 10:18



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 444 of 465
Page 26
144:19 403:20
million 185:14,17
185:18,19,23
mind 117:21 148:6
231:14 252:14,21
253:5 294:9
mindful 4:22
mine 13:20 14:7
107:25 121:17
265:12 266:15
333:23 353:2
miners 251:15
mini 72:9
miniscript 72:12,19
minor 25:5 83:3
85:19,22 90:19
164:15,21 165:3
168:21 170:19
172:7,14,20 173:4
180:8 181:8 183:2
184:6,23 224:12
224:18 237:13,19
238:7,23 239:5,9
239:11 254:10
354:3 359:13
387:11
minors 83:9 87:9
89:8 164:23
169:20 170:6
171:7,13,18
173:14 174:7,22
175:3,10,19 176:3
176:16 178:3
179:19 180:15
182:2,11,15
183:11 198:14
238:15,22 251:21
252:3,15,23 253:7
387:18
145:3,11
mischaracterizat...
225:13 227:12
323:22 341:21
mischaracterizes
320:14 384:4
mischaracterizing
226:3 227:5
misstates 15:17
106:7 355:21
misunderstanding
320:4
140:22
model 288:21
165:13,16
165:18,21
moment 10:16 36:8
75:5 115:11
116:25 117:18
147:22 206:21
224:3 230:24
286:2,4 311:5
317:24 385:2
398:12
monday 351:3
368:20
mondays 368:6
money 60:11 61:5
184:5 185:22
274:4 347:4
365:16 371:22
380:20
month 129:10
347:12 401:6
months 375:16
401:7
moot 367:6
morgan 2:16
morning 4:12
169:5
morocco 132:8,9
141:22,22
mos 405:23
mother 16:10,21
17:3,13,14,17,23
18:8,15,21 19:7
37:17,22 39:23
40:2,11 85:4
214:7,10 215:14
215:22 216:4
217:16,25 218:4
218:21 219:8
226:19,23,25
227:14 228:8
254:16 328:5
374:9 375:13
376:7,22 377:5
394:25
mothers 85:3,5
376:13
mouth 334:21
movable 288:21
move 54:7,9 124:13
175:20 179:9,15
moved 288:23
358:7
moving 65:4 66:18
multiple 76:9
multiply 228:19
N
n 2:10 4:6 168:4,4,4
168:6 414:3
37:4,16,17,23
38:17,19,21,25
39:4,10,18,25
40:9,15,17,20,22
41:14,17,20,24
42:13,17 43:5
44:16,22 45:5,8
45:11,15,20 46:3
46:6,13,17,22
47:9 87:5 145:10
145:19 147:10,16
255:4,19 396:16
396:18,21 397:2,4
397:9,10,12,14
naked 25:9 30:16
86:15 188:10,13
188:17 191:21
192:5,9,11 193:3
193:17,18,23
194:2,5,7
nakedness 190:15
name 3:19 25:5
40:20 55:18 63:17
85:16,19,22 127:8
128:17,22 151:9
156:9 160:14
161:12 162:3
164:13 193:6,9
198:6 211:25
212:3,20 236:9
260:12,14 261:2
261:13 272:22
275:15 304:19,22
305:8 306:19,24
307:3,5 326:5,6
342:7,10 371:16
372:16 388:23
named 49:9 217:10
217:11,17,20
names 73:7 114:20
130:25 164:23
166:16 314:3
319:21 320:17,20
320:22 322:20
324:10 331:20
333:18,25 388:21
262:4
nature 10:10 12:20
48:5 69:18 71:4
71:11 77:14 117:6
117:13 136:23
211:4 295:24
402:4
naval 129:15
377:17,19,24
378:3
near 413:9
necessarily 192:16
150:15
151:14
need 5:4 8:10 11:6
27:14 45:21 54:15
61:23 73:12 74:21
84:21 100:21
138:10,16 170:10
184:17,18,24
190:3 201:15
230:2 242:23
279:9 287:24
318:9 337:8
377:20 378:4
410:12
needed 66:21,21
188:3 258:3
316:16 317:19
322:9 360:6
needs 21:25 83:12
negative 389:16
nephews 30:24
339:15
nes 388:22
never 13:9 23:22
27:20 29:6 30:18
39:25 48:18 53:5
53:18 55:11 56:20
57:6 58:10 62:19
62:23 63:5 75:25
76:5 79:6 93:17
95:19 97:5,11
99:22 100:8
104:22 107:3
113:7 116:24
146:25 157:9,15
163:25 164:5
193:24 195:9,25
197:14 198:15,17
218:18 229:16
230:13 231:4
233:8 239:8,10
243:25 248:5
288:19 300:25
311:13,16,20
328:25 335:9,25
336:3,9 337:18
338:8,16 339:2,12
344:18 348:11
365:15,20 367:5
379:2 382:13
387:17 389:9,15
393:7 396:20,23
397:8 402:3 409:2
412:6
new 1:3,17,17,21
1:25,25 3:8,11
5:20 8:5 79:14,16
79:19,22 80:18,19
80:20,23 91:10
103:6 112:11,14



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 445 of 465
Page 27
112:22,25 113:18
113:20 118:23
134:19,20 156:21
157:14,16 189:18
189:19 190:17,17
210:8,12,15
248:19,19 264:12
264:13,19,23
268:25 271:9
273:17 287:17
293:17 318:15,15
351:9 375:19,20
381:22,22 389:4
411:9,16,21,24
412:7,18
news 210:21
newspaper 216:24
216:25 231:15
nice 184:19 191:15
nieces 30:24 339:14
night 140:17 155:5
235:23 379:4,6
403:15
nightclub 235:25
nipples 82:12,20
83:3
nodding 5:3
nominal 11:2
nonconsensual
55:7 62:18,19,24
63:8 64:5
nonconstitution
378:23
nonprosecution
395:6,9,19,25
396:6,9
nonsexual 246:8,16
nonverbal 5:3
normal 219:5
370:13
notary 1:20 4:8
417:14
noted 168:5 413:20
417:6
notforprofit 270:2
november 121:4
nude 189:15,23
190:7,11,13,14
243:15,21 255:21
number 9:23 13:19
84:3 110:18
119:19 129:9,12
133:12,17,21
148:21 150:7,16
151:17 154:2
158:7 159:22
165:14 167:2
168:16 209:22
258:25 259:4,7,24
260:2,2,16,20
261:2,22 266:4,17
269:2,5 297:7
298:14 315:7,17
317:2,20 318:15
321:5,7,15,21
322:8,13 323:18
324:2 327:12
353:9 356:3
numbers 24:24
144:20 148:22
149:18,22 180:19
261:18 266:15
272:25 314:24
315:21 316:6,16
319:22 320:9,12
320:16,20,22
332:13
nutritionist 60:16
O
o 168:4,4,4
object 6:5 8:25 12:2
12:24 13:13 14:4
14:12,20 15:16,24
16:7 18:3,18
19:12,19,24 22:22
23:4 24:2,13
25:25 26:9 27:12
27:24 29:9 32:4
32:25 33:16 37:5
37:14 39:6,13,19
40:3,12 41:15
42:21 43:2,17,24
44:25 45:16,23
46:8,19 47:22
48:3,8,15,21 49:4
49:11,21 50:7,14
51:3,8,16 52:5
56:3,12,18,24
57:9,16 61:22
69:19 93:11
102:12 105:18
106:6 120:19,21
122:19 126:4
163:20 178:4
186:12 194:14
238:24 240:3
243:3,16 248:10
252:4 253:2,3
255:23 260:17
269:18 274:7
298:18 308:5
326:25 334:13
337:21 341:20
387:14 390:2
objection 21:10
45:22 46:11,15
52:18 58:3,8,14
58:18 60:6 62:22
63:11 64:12 67:2
68:9,15 70:3,8,14
70:18 71:13 74:5
75:15 76:14 77:2
77:22 78:18 79:3
79:10,17,23 80:25
81:6,12,23 82:5
82:13 83:20 84:19
87:12 89:13 92:7
92:16,24 96:24
97:18,24 98:15,24
99:17,25 100:12
109:4,9,15 113:13
116:11,22 117:7
121:14,22 122:10
123:2 125:3
127:19 128:25
132:24 136:10
139:12 144:4
146:9 150:22
151:10 152:9,17
154:6,13 155:6
156:11,24 157:7
158:12,23 159:6
159:12 160:9,20
162:5,18 164:18
164:25 165:6,24
167:10,21 168:23
169:21 170:7,20
171:8 172:4,8,15
172:22 173:5,15
174:8 180:12
184:8 187:11,23
188:22 189:4,20
192:6 195:20
196:7 198:21
199:3,21 201:12
201:21 202:8,20
203:4,12,22
204:11,23 205:9
205:23 206:16
207:4 208:20
209:3 211:11,22
216:2 219:11
220:8,17 221:6,16
223:7 224:6 225:5
225:18 227:2
235:17 236:19
237:4,14,20 238:8
238:17 239:15,21
241:10,23 242:6
242:15 243:10
244:9,20 245:22
247:16 248:21
250:3 251:16,22
252:17,24 253:8
253:16,22 254:4
254:12,22 255:8
256:20 257:9,16
258:5,9,12,19
260:21 261:10,23
262:13,25 263:24
264:6 265:17
267:3,18 269:11
270:19 271:2,20
272:5 275:24
276:10,21 277:6
277:14,24 278:11
278:23 279:7,17
280:3,13,24 287:5
287:10,19 288:25
289:7,14 290:3,18
291:22 292:7,17
293:24 294:24
295:9 299:20
300:4,13 301:2,10
301:16 302:4,11
302:23 303:19
304:3,10 306:15
306:25 307:7,20
309:11,17 310:2
311:2,11 312:24
314:5,15 315:12
315:25 316:7
318:5,20 319:12
319:23 320:13
321:17 322:10
323:9,20 324:12
324:18 325:10,18
326:19 327:18
328:12,23 329:4
329:11,20 330:5
331:4,12 332:21
333:20 334:4,23
335:7,14,23 336:7
336:13,16,23
337:6,14 338:2
339:10,20 340:20
344:23 346:25
349:6,17 351:20
354:7,22 355:9,20
356:13,19 357:6
359:7,14 360:2
362:3,10 363:3,20
364:12 365:18
366:18 367:11
369:6,12 371:3
372:17 373:18
378:24 379:13,19
379:25 380:8
381:17,24 382:8



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 446 of 465
Page 28
382:19 383:6
384:3 385:5,11
387:6 389:13,20
390:9 392:3 393:2
393:11,18,24
394:9 395:11,21
398:24 399:8
401:3,25 402:9
403:25 404:11
406:5,11 407:5,11
408:2,7,13,19
409:9 410:10
411:17 412:4,11
412:19
objections 13:18
21:5 413:7
obligation 77:5
obligations 76:25
observe 29:15,24
30:10 38:24 48:25
98:11,21 114:22
136:2 167:13
256:3,4 397:14
observed 22:15,19
23:14,22 29:7
48:18 57:6 239:8
239:10 387:17
401:19 403:2
obtain 76:12
104:10
obtaining 100:6
407:3,9
obvious 200:23
201:10,20 202:6
202:16,24 203:8
203:18 204:3,8
205:6,15 207:2
208:24 209:9
210:20 211:8,13
211:19 212:7,8,12
212:13,15,18,22
212:23 213:7,21
214:18,20 215:6
215:15,16,20
216:6 217:19,21
217:23 226:17
227:6,7,10 229:24
230:4,17 231:20
233:2,11 235:3,4
235:8,14,15
236:17,25 241:21
242:3,10,14 243:7
243:14 251:13,19
251:25 254:9
256:17 257:5,12
299:19 300:25
302:17
obviously 149:10
161:17 207:16
216:12 217:12
238:12 247:8
286:6 311:16
316:10 384:19
385:19
occasion 397:16
occur 409:24
occurred 334:21
ocean 270:3
oceans 371:17
offender 184:2
359:20
offensive 226:9
offer 351:12,16,23
offered 365:16
office 5:20 28:25
50:3
officer 88:14
officers 88:5 90:8
offices 1:15
oh 230:7 250:14
300:25
379:5,7 403:13
403:18
oil 86:20
okay 72:18 129:11
131:22 132:11
151:23 179:16
353:5 385:18
391:24
olas 2:4
old 9:18 12:22
25:15,16 33:7
35:3 37:8,10,12
37:19,24 38:4
39:5 42:17 43:14
43:20,23 44:12
56:14 58:12,21,23
86:5 96:9 121:13
122:9 153:18
158:22 159:4,11
164:4 166:4 167:4
167:8,14,16,20
208:18,23 211:6
250:16,21,23
251:2 353:18
376:10 379:11
older 353:22
olds 165:23
once 25:14 78:22
78:23 116:6 312:7
372:4 401:6,7,16
ones 212:8,16
273:17 299:3
online 188:3
opening 210:2
opportunities
60:25
opportunity 60:18
60:23 61:24 169:6
368:24 373:16
option 61:3
order 4:22 102:22
200:15 360:7
375:24 376:19
413:13
orders 329:2
organizing 231:10
orgy 40:16 351:11
original 136:7
210:11,24
originally 130:22
217:10 307:13
outfit 68:23 69:9,12
69:13,16,17
111:25 117:5,5,9
117:12 233:8
236:18
outfits 68:19 69:14
236:23
outrageous 240:12
outside 7:17 17:14
17:23 18:8,21
102:15 116:17
136:25 189:25
190:18 200:6
214:10 215:21
218:20 219:7
226:25 227:16
228:7 237:7
281:22 293:20,21
372:11
outstanding 340:3
340:6
overnight 138:20
overseeing 12:11
oversees 276:7
279:14
owned 232:25
owns 354:17
372:24 388:5
P
p 2:9 34:12 168:5
373:10 413:19,20
paced 138:25
pad 147:23 151:2
160:14 162:4
414:21
pads 148:3 149:12
149:21 152:24
166:23
page 24:23 25:7
26:24 34:8,9,9,20
34:23,24 72:5,5
72:11,13,17 73:3
73:11 85:8 110:23
113:23 118:17
125:14 129:8,24
130:19 139:21,21
141:19,19 144:15
149:16 151:22
156:15 157:17
159:19 164:10
165:11 166:22,23
262:3 263:19
264:2,9 265:8,25
266:10,19 273:3
319:17 321:6
334:11 345:14,15
346:3,16,17
352:22,24 353:3
353:10,11 361:8
398:6 414:6,12
415:2 418:3
pages 119:17
127:25 128:6,9
147:24 148:24
263:12 414:21
417:4
pagliuca 2:18 4:3,3
5:17 6:5,13,22 7:5
8:25 10:15 11:4
11:17 12:2,24
13:13,18 14:4,12
14:20 15:16,24
16:7 18:3,18
19:12,19,24 20:25
21:10 22:3,22
23:4 24:2,13
25:25 26:9 27:12
27:24 29:9 32:4
32:25 33:16 35:4
35:8 37:5,14 39:6
39:13,19 40:3,12
41:15 42:21 43:2
43:17,24 44:25
45:16,21 46:8,11
46:15,19 47:22
48:3,8,15,21 49:4
49:11,21 50:7,14
51:3,8,16 52:5,18
54:15,20 56:3,12
56:18,24 57:9,16
58:3,8,14,18 60:6
61:22 62:17,22
63:11 64:3,12,21
65:12,16 67:2
68:9,15 69:19
70:3,8,14,18
71:13 72:7,23



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 447 of 465
Page 29
74:5,11,15,20
75:15 76:14 77:2
77:22 78:18 79:3
79:10,17,23 80:25
81:6,12,23 82:5
82:13 83:12,20
84:19 87:12 88:7
88:13,20,25 89:13
92:7,16,24 93:11
96:24 97:18,24
98:15,24 99:17,25
100:12,24 102:12
102:19,24 106:6
109:4,9,15 110:8
110:12,19 113:13
116:11,22 117:7
119:3,12 120:5,20
121:14,22 122:10
122:19 123:2
125:3 126:4
127:19 128:3,9,25
132:24 133:8,11
133:15 136:10
138:3 139:12
140:3 141:12
143:3 144:4 145:5
146:9 149:17
150:22 151:10
152:9,17 154:6,13
155:6 156:11,24
157:7 158:12,23
159:6,12 160:9,20
162:5,18 163:20
164:18,25 165:6
165:24 166:14
167:10,21 168:23
169:21 170:7,20
171:8 172:4,8,15
172:22 173:5,15
174:8 177:15
178:4,13 179:8,12
180:12,18 181:5,9
181:13,22 184:8
186:12 187:11,23
188:22 189:4,20
192:6 194:14
195:20 196:7
198:21 199:3,21
201:12,21 202:8
202:20 203:4,12
203:22 204:11,23
205:9,23 206:16
207:4 208:6,20
209:3 211:11,22
216:2 219:11
220:8,17 221:6,16
223:7 224:6 225:5
225:18 227:2
235:17 236:19
237:4,14,20 238:8
238:17,24 239:15
239:21 240:3,19
241:10,23 242:6
242:15 243:10,16
244:9,20 245:22
247:16 248:10,21
250:3 251:16,22
252:4,17,24 253:8
253:16,22 254:4
254:12,22 255:8
255:23 256:9,20
257:9,16 258:5,9
258:12,19 259:15
259:18 260:17,21
261:10,23 262:13
262:25 263:13,24
264:6,21,24
265:17 266:3,11
266:16 267:3,18
268:2 269:11,18
270:19 271:2,20
272:5 273:5 274:7
275:24 276:10,21
277:6,14,24
278:11,23 279:7
279:17 280:3,13
280:24 281:6
282:3 283:25
285:22 287:5,10
287:19 288:25
289:7,14 290:3,18
291:22 292:7,17
293:24 294:24
295:9 298:18
299:20 300:4,13
301:2,10,16 302:4
302:11,23 303:19
304:3,10 306:15
306:25 307:7,20
308:5,12,16,22
309:2,8,11,17
310:2 311:2,11
312:24 314:5,15
315:12,25 316:7
318:5,20 319:12
319:23 320:13
321:6,17 322:10
323:9,20 324:12
324:18 325:10,18
325:25 326:19,25
327:18 328:12,23
329:4,11,20 330:5
331:4,12 332:21
333:20 334:4,13
334:23 335:7,14
335:23 336:7,13
336:16,23 337:6
337:14,21 338:2
339:10,20 340:20
341:20 343:11
344:23 346:25
349:6,17 351:20
352:25 353:5
354:7,22 355:9,20
356:13,19 357:6
357:10,25 358:5
358:20,24 359:7
359:14 360:2
362:3,10,16 363:3
363:20 364:12
365:18 366:18
367:11 369:6,12
371:3 372:17
373:18 378:4,24
379:13,19,25
380:8 381:17,24
382:8,19,23 383:6
384:3 385:5,11
386:7,12,19 387:6
387:14 389:13,20
390:2,9 392:3
393:2,11,18,24
394:9,21 395:11
395:21 398:24
399:8 401:3,25
402:9 403:25
404:11 406:5,11
407:5,11 408:2,7
408:13,19 409:9
410:10 411:17
412:4,11,19,23
413:10
paid 25:10 49:17
50:3 51:2,5,25
67:18 75:7 87:3
184:5 185:3,4,10
185:12,14 237:2
263:6 265:16
270:5,7 277:13,18
277:19 339:18
340:5,12 343:3
352:5,9
palm 17:25 19:11
28:12,17 29:8,16
39:16 44:23 70:2
70:12,17,23 72:3
76:13,19 77:21
78:2 87:9,21
89:11 91:7 118:22
121:4 122:16
123:22 125:24
126:13 127:5,13
132:5 134:19
144:25 145:15
149:2 155:9,14,17
156:20 157:13
160:24 161:19
186:7,22 187:3,5
187:9 189:18
190:17 214:6
241:22 242:4
243:9 248:18
300:12 313:12
panties 86:17
paper 265:20 368:6
papers 197:4
216:23 227:8
228:4 252:9
paperwork 8:3,15
paragraph 25:7
26:24 34:23 35:6
86:8,10,11 87:2
210:13,23 386:3
paralegal 2:6 5:21
413:13
parent 191:9
376:11
parents 244:5
376:9,10
paris 132:7,7,7
141:21,21
parlance 357:15
part 20:12,19 26:13
26:15,19,20 31:15
62:3,16 76:16,24
80:8 102:20,22
116:19 139:9,17
150:2 169:23
213:7,24 214:19
230:15 245:25
246:3 284:6
319:16 353:11
participate 18:13
18:24 21:6,8 76:3
229:13
participated 63:4
76:6 100:8 229:16
229:18 345:5
participating 53:16
particular 235:21
410:25
parties 148:11,15
292:10
parts 209:25
party 112:25 146:8
146:13,15 148:17
223:18 291:19
292:4,9,11,12
360:6
pass 209:12 334:16



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 448 of 465
Page 30
passed 184:16
328:5 375:16,18
passing 328:6
passport 109:13,19
387:5,13,18
patent 69:17
paths 397:9
pattern 401:18
paul 2:13 3:25
pause 245:6 252:25
253:3
pay 25:12 29:3 50:4
67:14,14 75:10
184:25 275:18
340:2,10
paying 49:24 75:11
101:21,25 117:16
277:16 343:21,24
payment 49:19
50:11 102:4,7,8,8
103:10
pays 60:23
pbi 118:19,21
120:14 125:19
pending 8:15 27:7
100:24 256:25
357:8 358:6,25
penis 86:24
people 9:23 15:12
27:16 29:19 30:7
30:10,12,14,15,16
30:17,20 31:9,13
31:14 32:16 41:9
41:12 50:2,17
55:13 59:11,17
60:14,24 63:25
88:9,16 89:2
93:22 94:23 97:5
97:6 100:9 122:6
123:6 136:8 143:8
143:22 152:6
166:16 180:21
188:2,4,14 190:22
191:14 193:2,9,11
193:13,25 194:16
213:15 223:15
230:10,20 243:20
243:24 244:2
245:9,10,12,13,14
245:15 246:2,21
246:22 247:19,20
248:13 249:6,11
249:21 303:2
310:8,10,16,22
311:17 313:14
322:24 323:4,13
331:8,25 383:9,10
383:14,16,17
384:6,8,15 404:5
404:15 408:17
peoples 184:18
376:5
percent 18:25
135:8 137:6 183:3
228:2,12 229:9
230:11
perfectly 65:20
perform 27:11
51:14 52:8,13
53:22 66:25 82:3
93:8 97:23 98:14
98:23 140:25
246:15 304:9
307:11,18
performance 59:25
66:16
performed 25:9
50:6,12,17,19
51:7 52:3 53:3
409:12
performing 55:21
55:25 101:21
102:10 245:21
period 21:7 27:15
30:17 55:2 84:17
123:11 127:17
144:9 185:2 231:9
255:25 256:2
294:18,21 295:7
296:16,21 297:11
315:14 333:8
340:17 357:22
359:4 364:16,19
365:9 369:25
375:17,18 380:11
410:14
permitted 200:7
perpetrate 107:3
perpetrated 35:17
91:2 207:8,10
229:4 273:22
perpetrating 53:17
person 24:9 32:22
33:18 55:17 99:3
111:16 127:15
142:11,12,14,15
171:22 176:4,22
177:8 184:15
193:16 205:14
216:17 222:23
223:3 226:7
235:24 241:2
246:13 251:7,10
279:25 280:11,16
288:21 296:13
304:21 309:22
324:25 325:3,8
353:21,23 354:13
383:11,11
personal 88:15,25
89:22 102:15
119:4 126:9 176:6
178:8,15 179:24
213:22 268:4
269:24 318:11
319:2 331:22
332:5,12,24
333:17
personally 171:20
171:20 176:6
249:6 302:18
307:16
persons 353:20
383:14
202:10 204:2
275:17,18 346:10
347:24 348:24
361:5,16 391:16
405:14
phone 7:6 76:22,24
77:11,16 149:4
150:16 152:23
154:2 158:6
166:25 258:25
259:4,6 260:2,16
269:2,5 295:23
296:13 298:8
313:19 314:13,19
315:3 316:5,15
321:15 332:13
385:21
phones 59:12
307:22 310:17,21
310:23
phonetic 47:3
photo 133:6 143:9
143:10 233:7
414:16,17,19,20
414:23
photograph 110:15
143:13,15 191:24
231:23
photographed
232:2
photographs
191:15 192:10
255:22 256:5
photos 193:11
244:3,4 256:7
259:11
phrase 25:18,21
26:5
physical 7:25
207:24
physically 233:21
337:24 378:22
pick 73:17 108:7
128:5,9 212:22
picking 212:23
picture 109:20,24
110:3,6,11,17
113:21,25 114:3,9
114:12,14,16,18
114:19,21 142:3,6
142:8,9,15,18
143:23,25 176:10
191:8,11 192:15
193:17,21 194:3,7
231:24 232:4,5,7
234:10,12,15,18
234:21 243:22
pictured 142:6
pictures 144:8,11
188:18 189:15,23
190:7,11,22,24
191:13,18,20,21
192:4,15,22,25
193:2,7,11,14,25
194:13,16,17,19
243:15,20,25
piece 191:10
192:11 214:14
215:12 244:6,6
265:19 405:24
pieces 194:18
pilot 46:24 47:5
104:10 230:14
377:25 383:11
410:5,7
pilots 31:14 47:3
pinch 82:19 83:3
pinched 82:12
pinpoint 163:15
198:11
place 19:2,5 26:22
55:13 66:10,12
95:2 104:24
111:11 129:15
139:4 226:18
228:4 231:18
234:7 235:8,11
236:6 265:6
293:11
placed 165:19
places 132:21
plaintiff 1:6 2:4,9
2:13
plan 372:8,10
plane 38:20 47:14
106:2 108:23



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 449 of 465
Page 31
121:12,20 122:14
122:25 123:10,13
123:15,18 124:4
125:22 127:11
131:11 132:23
135:21,24 136:23
137:8,10,12 139:5
145:18 211:21,24
212:11,20 280:16
410:17
planes 38:18 41:24
42:5 43:22 47:12
105:7 122:2
127:12 135:10,11
145:22 146:2,4
211:10 212:5,17
409:22 410:8,18
410:20
planet 261:6
planning 285:12
please 5:22 6:10 9:4
9:7 23:12 28:7
34:23 65:14 77:24
83:14 85:10 94:7
105:20 111:18
131:18 142:3
168:25 169:24
181:20 198:23
201:24 202:23
203:7 210:3 214:5
220:20 221:25
242:2 243:6
244:11 252:20
253:18 258:15
262:3 266:4,17
267:6 269:14,20
270:21 287:7,12
289:9 312:18
336:19 345:11
368:7
pleasure 243:5
pled 184:13
point 10:10 40:23
40:25 76:6 101:4
103:9 148:10
226:6 247:2
250:22 295:4
307:14,23 384:20
399:25 410:18
pointing 126:16
police 24:10,15,19
24:20,22 55:21,25
56:16 83:6,9,15
83:18,22,25 84:4
84:6,11 87:20
88:4,16 89:9 90:7
164:23 166:20
168:16,19 169:4
169:10,11,12
170:12 171:4
175:7 178:20
180:9,14 186:21
187:15 195:22
220:4 221:8
252:10 255:10,11
344:4 346:21
347:18,19 414:13
pool 30:13 31:13
50:20 189:17
190:18 245:10
247:4 310:10
383:10 404:16
portion 72:12
portions 85:15,17
portrayed 78:15
position 75:6
178:21 207:24
215:4 299:18
389:12
positions 247:23
positively 205:2
possible 28:10
37:12 60:25
163:12 166:12
190:21 192:25
193:10 235:13
245:16 272:20,23
315:16 333:16,24
368:21 393:14
possibly 24:4,6
29:20 35:24 144:6
154:8,15 157:21
159:8 164:3 166:2
195:14 198:12
216:21 223:9
263:3 299:22
302:18 304:12
314:17 320:8
321:2 324:7
331:14 332:9,17
369:14 402:18
post 323:11 385:21
potential 386:22
potentially 50:21
50:22 130:3
389:17
pounded 207:20
pounding 208:2
practice 151:7
152:22,23
practiced 351:11
precise 7:9
preference 100:11
100:18 194:16
251:14,20 252:2,8
252:15,22 253:6
pregnant 337:2,4
337:12,25
premier 35:2
presence 22:20
287:3 288:5,15
289:12 290:16
296:8 302:3,10
308:11,14
presences 302:14
present 2:21 27:16
27:21 28:3 30:6
44:23 75:18 79:5
81:15,16,17 85:3
112:25 113:2
116:2 134:10,17
135:8 176:6
186:10 187:18
191:22,24 201:4
224:11,17 225:2
249:3,21 251:12
271:16 294:20
296:14,22 297:12
313:25 337:17
340:18 341:2
372:8,10 379:12
379:18 413:14
104:16
104:22 105:3,7
106:2 129:20
130:9,14,18 131:3
131:10 134:6,11
134:15,16,22
135:7,11,15,25
136:2,18 138:18
139:4,15 140:11
266:22 267:2,8,15
267:25 268:9
press 31:4 33:6
36:8 76:21 111:17
111:20 182:20
183:8 201:9,17,18
202:3,4 205:13
207:8,15 211:5
216:10 228:19
236:2 273:25
330:23 344:6,7,9
344:14,15,19,21
345:2,9 348:22
349:5,10,13,16,25
350:2,8,10,14,18
355:18 356:12,18
357:24 359:6,24
360:11,22 361:8
361:10 364:14,22
365:13 366:17
367:3,10 375:21
385:4,10,24,25
391:8 392:25
393:17,23 396:7
399:3 406:10,10
406:19
pressure 93:10
94:14 95:7 96:22
229:3
presumably 346:18
pretty 17:11
prevent 5:10
primary 155:22
63:9,15
80:23 106:15
107:4,7,10,12,16
107:19,20,23
108:3,11 110:5
111:8,12,15,25
112:10,24 113:4
114:22 115:3,7,10
115:16,17 116:3
231:18 232:6,10
232:22 235:4,9,16
235:23 236:3,3
286:24 287:3,9,16
288:5,16 289:12
289:22 290:11,12
290:15,16,22,23
291:13,16 292:3,5
292:15,19 293:6,8
293:9,10,14 302:3
302:10,22 303:11
398:8 399:5,18,21
401:2 403:4
265:11
print 405:23
printed 317:18
prior 223:23
346:19 348:25
350:3,12 352:22
124:19
privacy 30:13
164:24 404:15
private 20:13 39:11
389:17
privilege 274:12
286:8
privileged 199:6,24
199:25 274:9,15
274:20 281:2
282:25 283:3,16
285:15,18 363:6,9
394:11,16
probably 10:5
78:12 91:25
146:18 164:7
204:18 205:18
212:19 218:24



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 450 of 465
Page 32
298:12 396:19
problem 20:3 21:15
356:8,24 357:4,13
problems 197:20
procedure 294:3
proceeding 6:23
proceedings 413:18
process 7:23 8:2,16
149:3 152:7 153:8
284:7 368:22
372:3
procuring 172:20
produce 199:12
produced 24:18
34:5 110:9,18
129:4,7 133:9
149:20 150:2
209:17 283:22
285:19 286:4,6,10
319:25 385:15
production 148:23
profession 60:15
professional 24:9
31:17,19,23 35:3
41:9 60:17,19
220:20,25 223:16
223:20 225:8,10
225:16 226:11,13
246:8,16 248:16
279:20 310:8
383:9,17,18 384:9
384:13 416:11
professionally
73:23
project 12:7,20
371:17 412:10,13
projects 12:8,16,17
12:18 397:8
pronounce 129:17
363:25
pronouncing
129:18
proper 77:8 245:16
properly 77:7
properties 384:17
404:10
proposing 364:23
propounded 181:2
417:5
prosecutors 349:2
350:4,12
141:5
prostitute 173:12
359:18
prostitution 172:21
275:23 276:9,20
277:5,10,23
protective 102:21
375:24 376:7,18
413:12
prove 285:13 351:8
351:25
provide 28:7 31:7
68:18,22 69:3
97:17 98:3 100:5
117:4 118:14,25
153:20 344:7
360:21,22
provided 60:11
86:16 117:12
272:24 320:24
321:12 322:6
342:4 379:23
409:19
provider 60:20
providing 69:13
99:16 154:11
279:5,15,24
280:11 379:10,17
psychological
239:14,20,25
240:18 241:9
psychologically
237:12,17 238:6
public 1:20 4:8
210:16 417:14
publicized 210:21
pull 314:12 361:7
pulled 85:8
punitive 103:5
puppet 113:5,8,10
286:25 287:4,9,18
287:21,23,25
288:3,6,8,10,12
288:14,17,20
289:3,5,11,17,18
289:18,21 290:6,7
290:7
puppets 288:2,2,7
purchase 103:23
104:6 342:19
purchased 66:21
343:6 372:14
purchasing 343:16
purports 114:4
purpose 8:8 47:19
140:13 146:23
154:11 245:21
269:9,17,23
278:20 280:18
329:9,17 330:11
purposes 8:4,20
67:7 99:16 164:24
177:14 182:20
183:8 225:3
253:15 275:16,23
276:8,20 277:5,22
278:8 279:5,15,24
280:10 309:24
310:19 330:3
335:21 354:11
367:10 370:25
371:6 379:24
383:4,25 401:22
402:22
pursuant 1:14
pushing 33:6
put 21:2 25:12 36:7
73:17,17,18,21
133:5 161:13
171:9 182:19
191:8,9 204:2
205:13 207:15,18
211:17 227:8
228:17 274:6,18
275:5 289:24
300:22 312:18
315:8 342:10
356:11,17 372:15
392:21
putting 119:14
Q
qualifications
323:3,6
question 4:20 6:6
6:12,14 8:13 9:2,3
9:5 10:19 11:9
13:15 14:17 15:6
18:9 20:2 21:11
21:16 22:10 23:6
23:6,9,10,11 26:2
26:4,13,15,16,17
26:20,21 27:6,7
27:14 28:6 29:11
29:13 33:9,12
39:15,24 44:4,21
45:25 48:23 52:24
53:10,24 54:6
57:3 64:23 65:6
70:10 73:5 74:21
74:24 77:7,24
91:21 93:5,13,19
94:5,9,12,17
95:14 96:14,15
97:7,12 98:4,19
100:15,24,25
104:20 105:20,21
105:23,24 106:8
106:14 120:25
121:24 122:20
148:7 150:24
157:2 168:25
169:24 170:10,23
170:24 174:4
175:22 176:10,24
176:25 177:14,17
177:19,21,23,25
178:6,12,14 179:9
179:11,14,16,21
180:17 181:6,10
181:12,14,15
186:13 189:22
197:13,17 198:16
198:17 201:15
202:22 207:13
221:19,25 223:14
235:19 238:5,10
239:17 240:20
241:19,25 242:9
243:6,7 244:11,23
245:4,6 251:18,24
252:20 253:2,3
256:25 257:11
258:14 259:19
261:12 267:5
269:13 274:17
276:3,13 277:9
278:16 279:10
280:18 281:12,21
282:4 284:5
285:23 286:9
289:9 299:16
308:9 323:24
329:12 334:12
335:17 336:18
340:9,22 350:17
354:8 357:8,11
358:2,4,5,7,8,10
358:12,22,23
363:10,21 366:24
366:25 367:7
370:4,10,11 372:6
375:8 377:9 378:5
378:6 382:24
385:7 386:8,18,25
392:20,20 394:12
394:14,15,17
403:17 404:13
questioning 36:2
65:19
questions 11:16
20:4,21,24 21:4
21:16,23 22:2
53:12 54:11,13,25
59:5 61:25 93:2
94:2,4,18 119:15
126:19 133:18
169:9 180:24
181:3,21 192:21



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 451 of 465
Page 33
200:20 234:5
238:2 244:25
245:3 299:14
309:7 390:5
399:15 413:3,6,8
417:5
quick 327:6
quite 28:23
quotable 210:3
quote 159:25 165:5
167:2 201:10,20
202:6,13 369:2
392:10
quoteunquote
83:11
R
r 160:5 161:18
168:4 418:2,2
railing 234:23
raising 413:6
random 238:10
240:25 324:23
range 103:12 111:3
149:21 160:22
410:13
ranges 149:18,19
ranging 66:23
rape 348:25 350:3
350:12
rapidly 376:14
read 26:17,18 36:8
36:22 53:10,11
60:8 63:13 73:12
73:14,14,15 74:7
74:13,20 83:22
84:4,5,11 86:2,6
89:4,9,18 90:14
90:24 105:21,22
118:13 148:8
171:10,14 206:21
209:11 252:11
255:10 257:22
276:24 330:19,21
334:9 344:5,13
345:8 357:19
358:15,19 396:7
417:4
reading 74:10
87:15 88:23
120:14 132:16
145:5,6,7 178:6
358:21
reads 151:25 351:5
364:2 366:23
ready 73:24
real 231:24 232:5
233:7 291:15
really 42:8 100:20
106:20,21 108:24
153:8 183:6 188:9
192:19 195:4
231:22 289:19
292:10 296:15,25
297:18,21 303:14
306:2 308:19
309:14 341:5
342:12 343:8
347:16 394:3
396:21 404:19
reask 97:7 169:23
201:15 221:19,25
289:9
reason 7:9 35:22
44:12 124:7
163:18 176:19
258:3,10,16,23
305:7 411:25
reasons 182:22
352:5,7,10
recall 16:16,20 17:2
17:15,21 26:21
33:24 34:25 38:11
38:16 40:6,14,24
45:7,8,11 47:13
47:18 56:14 59:9
59:14,21,22 61:6
61:13 67:17 75:2
75:11 80:3,16,17
80:22 81:3,19
98:8 101:23 102:2
103:14 104:4
106:10,11,21
111:4,7,11,22,23
113:4,19 114:25
121:3,6,8 123:9
125:24 126:12,24
127:11 130:4,7,9
130:13,16 131:3,9
132:18,20 133:3
133:15,25 134:6
134:25 138:18
140:17,18,19,21
141:7 143:2,12,15
144:7,9,10 145:14
145:18,21 146:5,6
146:11 148:15
149:2 153:8 156:9
157:2,4,5 167:17
185:8,11,13 186:9
191:19,23 192:3
192:24 193:19,20
194:6 195:10
197:16 206:12,23
212:4 213:11
227:13 234:2,15
234:18,22 242:12
262:11 280:15
285:7,10 290:24
297:18 298:2
299:3,4,6 301:4
305:3 306:7
308:19 309:14
311:4,24 319:8
320:11 333:12,15
341:5,6,7,10,11
341:16,18,23
342:6,8,9,12,16
342:18 343:8,17
343:18,19,20
360:23 369:18
373:11,22 377:6
378:16 382:10
387:2,8,10 388:11
388:12,20,25
392:8 395:2
396:17 397:24
398:14 399:17
402:19 404:25
408:21 410:3
411:3,7,12,20,22
recalled 36:14
recalls 268:8
receive 7:24 31:23
149:7 223:5 246:8
278:9,21 308:17
received 78:21,25
263:21 363:11
receiving 222:21
recess 67:24 118:3
168:3 208:14
256:13 294:13
327:9 373:8
recognize 143:19
143:21,22,23
229:5 232:4
261:18 263:23
264:3,8 307:5
320:17
recollect 10:4 35:21
36:12 42:2 44:13
49:6 70:20,22
71:5 75:21,23
78:14 79:19,25
105:10 108:8
113:3 136:6 137:3
138:23 139:2,3,8
141:3 147:16,19
148:10 151:12
188:17 270:11,14
270:17 271:4
272:7,8 275:10
282:8 290:5,5,6
290:10,13,20
291:11,15,16,17
291:20 292:2,2,3
292:9,11,14,19,20
292:21,24 293:3
295:25 301:22,24
303:6,8,10 304:12
304:21,24 305:2,4
306:18 307:15
311:20 312:5,12
318:13 319:3
338:20,24 339:4
339:25 341:3
360:17 361:13
378:19 380:10,14
380:17 385:21
399:25 400:18,21
400:22 404:19
406:17 408:25
409:2,5,17
recollection 16:14
16:19 25:19 36:13
45:3 50:15 61:19
67:12 69:12 74:2
74:16 77:13,18
108:13,25 109:17
111:20 112:18,20
112:21 126:15
128:2,11 138:21
139:7 147:15,16
159:17 160:16
161:3 163:13
188:13 193:13
227:15 232:21
243:13 265:14
271:25 280:19
306:20,22 307:24
331:25 350:21
366:10 372:19
378:18 387:20
407:7
record 3:3 4:21 5:5
5:23 6:17,21,24
6:25 7:3,8 8:8,19
26:18 53:11 54:18
67:23 68:2 76:8
85:20 105:22
111:15 116:24
117:24 118:2,5,16
119:11,14 126:5
128:17 137:23
141:12 148:8
152:15 154:17,20
157:24 168:2,12
174:5 177:22
178:5 180:20
181:17 207:19



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 452 of 465
Page 34
208:7,13,17
212:20 230:12
256:12,16 263:13
266:13 294:12,15
309:4 327:8,11
358:9 373:7,10
386:21 389:10
390:17 413:3,19
416:7
recording 3:3
records 129:4,6
166:17 180:23
195:23 211:24
221:8 318:24
recover 408:18
recruit 6:3 8:24 9:7
25:22 26:7,14
46:17 56:21 81:22
82:3 93:16 94:10
94:14,21 95:6,10
95:17,18 96:21
97:3,4,11 253:14
253:20,20 254:2
recruited 9:15,20
93:18
recruiting 93:8
redacted 25:3,4
27:4 85:14,17
88:21 156:19
164:14,24 166:15
166:17 180:23
398:13
redaction 85:18
398:16
redactions 25:2
redress 211:6
refer 183:16 265:25
266:6,10 316:25
reference 231:14
318:8 336:2
referenced 88:16
150:7 159:4
referencing 139:16
189:8 252:12
332:5,25 386:16
referred 267:23
317:24 398:9
referring 9:13 33:4
41:6,19 71:16
77:6 82:15 89:23
90:24 123:20
143:5 154:5
155:12 156:22
158:21 159:2
160:13 194:8,9,11
209:6,8 221:9
230:5,18,19,20
242:19 243:19
278:13 316:19
327:20 346:23
349:12,12 350:7,7
364:5,7 368:9
406:4
refers 386:3
reflect 141:13
181:17 309:5
reflected 162:3
reflection 206:23
reflects 118:17
209:19 268:10
refresh 36:13 74:2
74:16 128:11
265:14 366:10
refreshes 127:25
refuse 177:16
386:17
refusing 54:5,11
65:5 176:23,25
177:18,20 386:21
regard 400:10
regarding 350:11
352:13 357:23
359:5 407:9
regardless 336:11
336:21 378:9
regards 204:4
303:2,3,15
registered 184:2
359:19 416:11
regular 305:10
401:10
regularly 66:2
77:17 121:19,25
122:4 123:15,18
147:11 162:10,15
162:22,25 165:22
187:13 393:9
400:25 401:5,11
401:13
rehashed 229:9
relate 54:25
related 173:4 195:2
270:3 332:20
333:11 343:24
352:16 372:25
relates 197:19
238:11,12 284:15
284:16 333:14
388:14
relating 20:9
213:25 332:14
344:4 407:4,21
408:11
relation 186:21
relations 63:8
181:8 196:13,16
196:22 197:9
210:18 228:3
354:2,3
relationship 10:11
47:25 48:6 57:14
57:18 91:15 101:9
101:11,12,12
135:23 137:19
138:2,4,6,9 272:9
294:22 295:6,15
295:18 305:16
353:19 354:15
381:2,8,11,14,16
381:19,20 386:5
386:16 397:6
401:23 402:21,22
402:25 407:23
relationships
137:22
relative 402:15
relatives 402:17
release 8:16 361:8
361:10 399:4
released 275:9
releases 356:12,18
relevant 21:24
284:8 315:22
336:5
remain 102:4
258:11 413:4
remains 210:25
remarks 145:2
remember 5:6,15
8:10 17:3 27:3
35:19,25 36:18
38:8,19 44:3
78:11,12 79:21
80:8,10,12,18
86:15 101:22
106:22 108:17,19
112:13,24 113:17
116:6,9 122:8
125:10,12 130:3
139:11 140:10,13
153:17,21 156:23
185:16 186:14,15
193:15,16 197:19
232:18 233:10,21
266:25 267:7,11
267:13 281:25
290:14,22,23
291:25 293:9,9,10
294:6 297:21
299:2 305:7,24
306:3,6,18 322:15
324:8 343:13,15
377:8 388:14
412:15
remembered
206:19
remembering
125:8
remind 5:8
remotely 190:24
removed 188:19
211:16
repeat 13:15 15:10
18:20 22:10 26:16
39:15 85:10 90:22
93:13 98:19
105:19 121:24
168:25 174:23
175:4,12 176:4
189:22 239:17
241:25 257:11
266:17 267:5
278:15 279:9
336:18 377:9
repeated 19:6
228:18
repeatedly 19:3
87:25 241:15,18
repeating 200:22
repetition 211:6
replacing 141:13
report 24:11,16,19
24:20,22,24 25:3
83:7,16,22,25
84:4,7,11 87:20
168:17,19 169:4
169:10,11,13
170:12 171:5
178:20 180:9
220:5 344:4,5,8
345:4,9 346:22
347:18,19 414:13
reported 55:12,14
111:19 235:25
330:22
reporter 1:20 3:15
3:18 4:18 413:15
416:11,19
reporters 142:7
reports 83:18 84:7
88:4,10,17,22,24
89:8,18 90:7,15
90:25 108:22,23
164:23 173:24
175:8 180:14
252:10 255:10,12
255:15
reposition 124:17
repositioning
124:20,22



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 453 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 454 of 465
Page 36
150:6 151:22
156:16 157:18
159:20 164:9
165:11 166:21
47:15 48:17
48:18,25 49:8,17
56:21 57:4,6
255:3,19 328:21
328:25 329:2
378:11,21 395:16
396:5,9,12,14
411:15,21 412:9
412:17
saturday 366:5
398:23 399:2,13
saw 38:12 53:18
75:25 79:6 201:3
201:5 223:19
291:12
saying 30:20 35:14
61:6 69:9 90:6
95:12 122:15,18
123:25 124:5,6,11
125:5,6 139:25
150:17 154:25
197:23 200:16,23
202:16,24 203:8
203:18 205:4,6
206:25 208:24
211:8,13,19 215:4
216:22 217:18
219:17 221:10,11
224:16,17 233:11
235:2,14,20
236:16 249:16
250:9 274:14
293:7 299:6 303:8
303:10 329:24
339:5 343:13
348:4 356:24
361:21 365:13
says 25:8 34:11,12
34:15 72:16 73:4
82:9 85:23 86:5
86:11,12 87:2
108:23 118:19
120:9 122:17
124:8 125:18
129:22 132:15
140:4,7 144:17
150:12,13,13
151:2 153:25
154:2 156:17,18
158:18 159:25,25
160:6 164:12,14
165:14 167:2
197:21 204:7,8
205:15,17,21
209:7,9 210:2,6,9
210:14 262:8
264:11 265:10
266:5 302:22
303:2 319:20
321:5,8,9 331:10
345:20 346:5,17
347:19 348:16,25
349:3,21,23
353:14 356:7
361:17 366:6
369:2 391:17
398:11 399:12,13
405:18
scandal 374:14
scarf 340:25
scenario 292:13
scenes 405:19
scheduled 92:5
scheme 253:13,19
253:25
schiller 1:16 2:3
3:13,21
school 68:23 69:8
69:11,13,16
236:18 307:25
310:24 311:9,14
311:14,15,17
353:16
schultz 2:6 3:21
scroll 125:18
353:10
se 243:21
search 186:6,11,14
186:16 187:15
188:20
sec 408:12
second 26:13 34:23
35:6 99:9 140:7
149:16 169:23
215:11 219:6
229:12 264:9
266:16 326:4
346:16 353:3,11
353:24
secondly 44:10
secret 230:9 293:15
294:4
secretary 383:11
section 319:19,22
320:18,23 324:3
security 293:16
see 25:2 29:22 30:7
34:20 53:10 71:22
85:14,17,25 86:4
86:9 87:6 89:21
108:23 110:23
120:14,16,16
124:14 125:17,19
125:22 127:25
128:15 129:14,16
129:19,20 130:19
130:20 131:19,23
131:24,25 132:2,5
132:14,19 133:17
138:24 142:22
144:17,19 145:3,9
145:12 149:19
150:12,14 153:8
164:12 165:12
166:24 190:25
191:4,12 192:14
208:8 209:23
212:3,20 219:22
223:2,12 231:13
234:17 246:22
260:25 264:10,17
264:20,24 265:3
265:10 266:2
267:24 268:13,14
269:9,16,22 287:3
305:10 313:6
321:3,5,10 345:16
345:24 346:3,4,5
346:10,14 352:23
353:11,17 356:4,7
368:12,25 376:22
377:5 391:11,19
391:20,22 392:15
397:23 398:5
405:10,16
seeing 40:15 75:21
75:23 79:21
133:16 138:8
147:6 156:9
404:19
seek 211:6
seen 23:7 24:19
30:14,15,18 39:25
40:7,9 53:5 55:11
108:22,23 110:19
110:21 144:2
173:23 271:5,23
271:24 285:4
288:4,14,19,20
289:3,5,11 305:5
379:2 402:3 404:9
409:18
sell 76:21 273:25
selling 7:23
semi 190:22 193:18
194:10
send 34:17 57:24
298:3,6 304:14
345:21 346:7
410:22
sending 354:10,19
sense 23:22 257:25
sensitive 11:10
sent 167:8 209:24
256:18,23 296:21
297:10,14 303:17
304:8 385:20
411:24 412:6
sentence 361:17
sentenced 172:2,11
172:18 359:16
sentencing 33:9
separate 156:7
374:12
september 256:19
264:23 266:6,19
267:2,8,21
sequence 395:2,3
serial 105:17
series 298:22 309:6
serious 240:13
seriously 193:19
served 172:7,13
service 230:9
293:15 294:5
services 1:24
set 69:14 74:22
133:20,23 147:21
148:20 162:15,22
176:17,20 177:10
177:12 373:23,24
374:6,24 375:4,20
376:21 377:3
401:18
setting 176:9,14
settle 184:5
sex 9:10 38:21,25
46:6,13,18 52:21
52:25 53:13 55:2
58:7,11 61:14
62:3,19,24 64:2
64:10,16,19 65:8
69:25 70:6,12,17
70:21,22 71:2,8,9
71:12 74:3 75:3
76:3 83:2 87:4
94:15 95:8 96:23
100:11 115:4,7
116:21 117:3
158:21 159:3,10
167:20 183:11
184:2 197:15
198:14 204:9,21
205:5,21 215:24
216:6 226:24
227:23 232:11,15



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 455 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 456 of 465
Page 38
speculative 241:4
spending 173:8
spent 18:7 138:7
173:2,3 365:11
367:13
spoke 17:14,22
158:19 164:3
296:18 297:19
305:19 396:13
399:10,20,25
spoken 195:13
365:15,21
spring 112:14
square 72:15
squares 72:20
st 115:13 134:3,3,5
stack 252:9 273:3
356:3
staff 11:23 55:14
116:15 156:21
157:14,16 187:8
187:10,21
staffing 184:22
stamp 34:11
stamped 85:9
stand 66:22 123:4
standard 294:3
401:17
standing 18:20
215:21 218:4
227:16 228:7
234:20
start 96:22 100:11
124:14 132:4
190:6 220:2 368:3
started 10:9 96:18
358:20 372:24
starting 68:2 118:5
139:23 144:14
168:11 208:16
256:15 266:20
294:16 327:12
346:14,15
starts 144:23 215:9
state 1:20 3:16 5:22
91:8 103:7 104:24
111:14 119:10
192:5,9,23 193:18
193:23 194:5
215:17 226:2
227:25 241:3
268:24 344:15
386:21 413:2
stated 25:8,14,16
27:2,3 84:11
86:16,23 87:3
202:5 225:24
280:21
statement 35:9
55:20,24 95:25
96:4 178:22
200:22 201:8,17
202:3,11 203:15
205:12 209:6,9,11
209:17,24,25
210:3 212:24
213:13,24 214:5
215:8 230:6 235:3
241:4 273:2,7,12
273:15,18 274:6
274:18,22,25
275:2,3,9,16
281:17 302:9
329:19 330:3
346:5 347:9 348:3
348:6,8,10 349:10
349:21 350:11
357:11,18 358:14
358:14 359:23
361:6,11 362:7,23
365:17 366:16,21
367:2,4,8 374:8
385:3,8,24,25
386:10,13 391:23
391:24,25 392:7
392:20,25 393:5,7
393:9 394:22
399:23 405:25
statements 198:19
198:25 199:18
213:23 215:10
356:11 357:23
359:5,10 360:12
360:22 393:16,22
states 1:2 34:24
98:13 132:21
210:23 268:22
276:6,16 279:13
363:17 371:9
372:9 377:11
392:19 399:2
stating 201:9,19
355:24
statute 353:21
354:10 355:8,13
355:24
statutes 355:4
stay 28:16 80:19
81:10,18 108:14
138:20 140:17
156:20 157:13
262:9 293:21
379:4
stayed 80:21
138:19,24 139:2,3
139:4 379:6
403:14
staying 28:21,23
81:19 155:23
262:10
stems 175:17
step 6:19
stephenville 132:5
132:6
stewardess 140:23
sticker 141:10
stimulate 243:4
stole 330:17,19
347:4
stolen 316:11,18
317:3,8,14,25
330:16 408:18
stomping 208:2
stood 218:20
stop 66:14 74:9,13
93:17,18 94:11
208:6 214:11
stopped 187:13
stories 31:3 35:17
44:9 76:21 108:9
111:17 175:5
235:21
story 33:5 80:2,7
82:8 108:5 180:5
182:6 206:3
207:11 210:14
215:22 216:8,9
218:18 226:18
228:8,16,18,23
229:8 230:8,9
235:7,22 253:12
274:2,3 290:20
328:15 344:10
349:13 350:8
351:14,19 373:17
376:2
straddle 27:14
straight 266:13
strategy 389:4
street 2:14 5:24
strike 23:10 98:9
strings 288:23
strongest 351:9
strongly 211:2,3
study 130:11
stuff 36:22 302:16
351:10
subject 6:13 20:4
20:14,20 53:14
103:25 135:4
200:2 209:21
241:7 348:25
350:3 362:25
370:23 399:6
subjecting 362:8
subpoena 1:14
373:23 374:3,21
374:23,24 375:4,5
375:14,19
subpoenaed 373:12
373:16,22 375:11
subscribed 417:11
subsequent 320:9
substance 400:9
417:6
substantial 12:19
suddenly 217:7
suggest 218:17
suggested 375:23
suggesting 9:9
138:12
suggestion 369:10
suggests 351:17
suit 93:25 176:13
346:19
suits 374:15
sunday 34:6 345:17
supervised 328:25
supervising 328:21
supervision 416:18
supervisor 328:11
328:19
supplied 341:19
supply 341:24
suppose 166:12
supposed 149:6
152:24 153:2,5,9
211:17
sure 5:8 13:22
17:11 54:18 65:23
66:12 74:8 84:24
85:11 119:24
123:25 124:6
125:7 129:18
136:4 137:9
139:17,20 142:11
168:16 169:25
198:8 201:16
209:12 214:12
222:22 232:5
244:12 254:25
271:6 274:21
276:2,13,23
278:17 279:11
287:8 297:25
303:12 315:18
337:23 338:4,6
347:16 348:12
354:18 360:18
366:13 373:3



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 457 of 465
Page 39
402:12
surfing 372:13
surprise 325:14
surprised 39:9
325:24
surround 385:13
385:17
surroundings
114:6
swaine 391:9,13
swap 141:11
swear 3:18
363:18
swimming 30:13
404:16
sworn 4:7 416:6
417:11
system 183:8
T
t 168:4 414:10
418:2
tab 119:23
table 86:13 207:21
208:7 228:25
tail 232:8 282:17
take 4:19 18:23
19:5 30:14 55:3
65:13 67:20 74:18
87:16 92:5 94:14
95:7 96:22 109:24
114:11 117:21
127:24 131:21
141:10 149:6
152:6 153:2 154:9
161:16,17 162:10
163:2,6,16 170:17
176:9 181:20
189:15,23 190:6
190:11 191:20
193:11,21 194:3
194:12,15 207:22
208:8,11 226:18
228:13,14 231:14
233:12,13 255:21
256:9 259:23
263:10 294:9
312:17 322:18
327:5 329:2 373:2
374:10 385:2,2
taken 1:14 3:11
113:25 114:4
143:16 149:9
150:12,25 151:7
160:12 163:12,25
164:5 166:3
191:16 192:4
193:24 254:11
404:16
takes 93:9
talk 4:23 7:6 33:18
46:22 53:14
174:18 175:6
176:7 182:5,9,13
182:16 183:4
195:17 197:22
204:25 206:2
220:19 296:4
297:23 302:19
303:3 362:17
365:12 376:16
399:14 400:2
talked 115:11
169:18 170:4,9
171:21 176:5
219:19 232:6
255:3 272:11,18
296:3 298:23
301:20 302:8
313:10 362:21
403:4
talking 10:16 11:5
17:16 18:7 23:2,3
23:19,21 25:21
41:12 64:21 68:20
68:25 69:6 70:25
75:5 82:16,21
93:21,23,23 94:25
96:6 98:17 99:21
121:16 123:21
126:17 128:3
136:3,14,15,20
137:21 139:10
141:16,18 154:16
159:14 168:14
170:2 182:12
188:15 189:7
195:22 214:15
215:21 216:4
217:16,25 219:7
219:13 220:23
229:24 254:7,24
258:7 264:25
265:2 278:2 279:2
286:23 300:24
302:25 308:7
313:11,21 327:13
329:13 330:24
335:18 337:9,23
340:24 342:11
343:7 350:22
375:7 377:24
381:4 382:14
411:11
talks 198:6
tall 45:10
tallying 107:15
tasked 60:2
tasks 59:24 66:16
158:6,8,10
158:14 159:25
161:9,10,11,21,24
63:18 65:21
120:18 121:9
126:2 127:6
142:19,24
tea 236:4
teach 167:3
teacher 167:2
teb 118:19,22
120:15 144:24
teenagers 225:15
225:22
telephone 257:7,14
315:6,16
telephones 60:3
307:14 309:21
310:14,15
tell 29:20 35:18,24
40:19 42:8,11
43:14 56:16 60:10
61:4 77:15 89:22
91:2 114:17 115:3
115:6 125:7 142:5
151:3 152:19
157:21 159:10,16
171:14 173:17
196:10,12,18,19
196:21 197:14
200:11,13 206:2
219:3 230:5
232:10,14 241:13
253:11 263:3
268:7,13,14
274:19 286:14
303:22,22 305:9
320:8,21 324:6
327:24 331:14
334:19 338:22
351:23 357:17
358:12 363:8
364:21 373:16
394:7,19 395:24
398:11 400:6
telling 180:9 200:4
203:14 205:21
235:15 281:12
299:4 331:9
354:25 362:20
369:5,19 409:5
tells 283:4
term 32:21 138:4
386:4,16
termed 20:6
terms 184:22 246:2
terramar 371:15
371:20,22
terrible 177:8
182:21,22 183:6
229:8 240:6
testified 4:8 33:23
39:21 41:5,21
42:15 43:13 44:2
44:15,18 47:13
58:20,22 59:14
62:23 69:5 87:18
89:16 99:12 100:3
101:15 103:14
105:16 114:13
123:17 133:2
153:16 162:12
163:5,8 168:7
174:13 178:15
186:17 194:15
197:10 206:11,18
212:2 230:12
235:23 236:21,23
243:21 245:8,24
248:12 262:15
271:24 273:9
283:9 295:3
300:17 306:17
307:12 309:13
310:7 318:22
320:19 328:4
330:13 331:6,18
339:16 387:8
404:14 406:21
testify 23:18 24:7
30:25 46:5 59:3
63:2 78:7 81:14
83:23 84:5,9,10
86:3 89:19,21
90:13,14,15 95:2
95:22,24 96:2,3
105:17 112:16
119:9 122:5
123:12 124:10
125:8,13 127:2
128:14 129:3,6
156:14 161:11
165:8 173:22,25
174:3,11,14 177:2
178:19 182:19,23
187:17 195:14
196:14 201:3,6,6
203:25 204:3,14
204:16 205:14
206:8 212:10
220:24 221:2,3,11



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 458 of 465
Page 40
221:13,20 222:3,5
222:6 223:9,15,17
223:19 227:5,20
228:11 237:6,7
238:19 239:6
240:11,15,25
241:16 243:19
245:15 248:23
249:2,5 252:6
255:13 265:19,21
267:12 268:12
271:8 272:8
281:25 294:4
298:21 299:22
301:12 314:7
316:9 324:14
325:20 328:2
329:22 330:7
332:17 333:7
335:22 336:6
337:16 338:17
347:16 350:8
387:15 402:13,18
402:24 403:5
410:19 411:19
testifying 27:8 29:6
90:9,10 95:21
123:24 178:11
204:13 239:2
249:20 338:16
testimony 5:10,15
8:11 15:18 16:22
16:23 35:11,20
36:11,17 40:5
83:9 90:17 122:23
123:19 124:24
126:23 128:22
130:13 157:23
161:15 183:14
193:16 214:13,21
272:2 280:20
282:11 299:13
320:4,15 323:23
334:10 338:15
341:22 343:4
352:5 355:22
374:4 376:20
384:5 416:8
teterboro 118:22
121:5 122:16
123:22 144:24
145:14
text 298:3,6 346:15
401:7
thailand 131:5,9
139:11,11,19
140:9,10,17,20
256:18,23 257:8
257:15,19,20,22
258:8,18,21,22
262:8,12,17,19,21
262:24 263:6
265:15,24 267:16
268:11
thank 7:18 34:15
346:5
262:4
thats 5:6 7:21 9:13
11:8 12:20 23:9
26:12 30:4 55:2
80:15 83:22 85:18
85:20 88:18 91:21
94:17 95:19 119:5
124:6 138:15,16
140:2,3 142:22
152:5 153:10
164:20 168:15
172:10,17 176:18
183:21 196:25
199:14 208:2
212:4 215:15
216:5,13,22
217:19 218:6
224:20 227:15
231:24,24 232:5
241:5 245:8
252:10 266:11,15
267:9 273:20,23
275:2 277:13,19
280:18 282:7
285:6,15 286:8
302:14 307:5
310:4 312:5
337:10 338:6
339:13 340:8
343:4 348:16
349:11,12 353:9
357:3,10 358:23
362:18 365:25
370:4,19 371:16
372:6 373:20
374:12 375:4
384:11,12 401:21
402:7,15
theft 344:3,8,12,17
344:22 345:6
346:21,23 347:7
347:10,11
therapist 32:12
60:17
therapists 31:17,20
31:21 32:8,10
51:2,11,13,20,24
52:7,12 53:3
69:15
therapy 50:24
theyre 21:18 275:7
286:21
thicker 266:8
330:15 352:19
thighs 86:18
thing 76:10 159:18
174:17 182:9
184:19 226:10
230:11 332:18
336:9 337:24
339:24 357:20
358:16,19
things 15:12 52:17
66:20 69:16 73:8
76:9 82:17 86:3
169:18 170:17,18
176:5 178:19
179:23 193:12
196:2 197:22
200:6 202:14
212:3 235:11
236:5 240:6
259:10 303:3,7
335:17 375:22
384:9
think 6:20 56:25
60:14 67:20 72:9
77:8 81:8 91:22
96:17 99:7,8
100:14,18,23
107:8 113:23
117:9 118:7
119:16 120:8
133:25 134:3
147:21 166:18
168:14 170:24
173:8 185:16
190:3 195:5
196:10 198:5
204:20 206:18
208:10 211:14
212:19 218:21
224:8 225:13
226:6 230:7 231:7
231:8 232:19
246:4 247:2,5
248:3 255:2
271:18 275:17
279:19 282:15,23
284:14 286:8
291:5 295:3,11,12
295:13 312:5,8
313:6,16 326:12
339:22 349:11
350:7,15 353:15
353:15 354:9,17
354:24 355:4,23
366:8 375:16
378:19 382:13
383:21 384:12
388:24 390:11
391:24 396:2
397:10 400:8
410:16 412:23
third 25:7 229:12
thought 34:24
118:10 214:3
246:10 273:17
320:4 330:8 355:3
400:6
thoughtful 184:19
184:24
thoughtfulness
185:24
thousands 182:8
193:10
threaten 54:16
208:4 335:3 336:6
threatened 335:10
336:3
threatening 54:17
335:21
threats 207:25
three 85:14 127:25
322:19
threepage 391:4
thrilled 213:2
time 3:9 7:12 9:15
9:25 10:11,23
12:9 16:24 17:3
17:23 18:7,14,22
19:7,10 21:7
27:15,16,20 28:10
28:18 30:6,14,14
30:15,16,18 31:16
31:16,22,22 34:11
36:24 38:9,11,13
38:16 42:25 43:5
45:4 48:10 51:11
55:10 62:25,25
63:7 76:5 77:12
78:5,7,13,13
80:21,21 84:15,15
84:17 87:22 88:5
90:2,18 91:5
92:14,14 95:4
96:6,13,15 97:20
98:10,20 102:5,11
103:22 104:7,23
104:24,25 105:12
106:3,4,18,21
107:5 109:3,7
111:9,19 116:25
121:10 125:9



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 459 of 465
Page 41
127:17 130:11
131:21 134:10,21
138:8 146:19
148:16,25 149:8
153:3 154:20,20
154:23,23 155:17
158:11 163:11
165:19 168:5
171:2 172:7,13
173:2,3,9 185:2
190:24 191:14,14
195:6,16 210:14
219:8,14 220:13
220:14 223:11
224:2,2 226:15,16
226:24 227:12,17
228:8,10,13,14,20
228:22 229:5,7,11
229:12,12,13,17
229:19,25 230:15
230:15,22 232:24
236:2 245:13
246:14,14 251:11
254:10 255:21,25
256:2 261:22
266:7 267:16
268:9,17 271:4
276:24 279:20,20
280:22 281:5,17
281:23 282:13
283:5,10,23
284:12,19,25
285:20 287:13
291:20 292:4,15
294:17,21 295:4,7
295:20 300:11
305:19 313:24
315:5,15 316:13
316:21 319:7
325:2,5 333:8
340:17 341:6
342:2,11,13 343:9
343:15 347:15
357:22 359:4,11
361:23 363:19
364:4,16,19
365:11 367:13,19
368:16 374:24
375:4,10,17,18,20
375:25 376:5,8,15
376:22 381:11
382:14 390:15
396:13,17,19
397:2 402:11
403:8,12,17,19
404:15,15 409:20
410:9,14 412:24
413:20
timeframe 293:12
times 40:7 42:4,6
42:13 43:21 44:6
50:16 61:12,13
76:20 78:16 79:8
90:23,23 91:6,22
110:18 115:20
116:5 123:10,12
137:11 160:16
164:4 167:4
205:18 251:10
254:20 255:6
296:7 305:5
324:23 409:21
timing 12:17
130:11 146:20
377:8
tiring 138:25
tissue 82:8 108:6,9
tist 125:19,20
title 353:7
today 3:9 5:11
35:18,19,20 36:10
36:11,17 37:2
65:24 97:14 99:6
108:17 124:3
156:20 157:13
167:6 168:17
176:11 191:2
194:19 202:12
206:24 208:22
224:9 283:9 295:3
299:13,19 339:16
372:2 381:4,5
388:8 395:16
398:9 404:13
409:19 413:3
todays 413:18
told 25:13 38:15
40:14 45:7 63:5
75:4 81:3 86:13
90:5,21 94:21
95:11 135:6,6
185:11,21 194:25
196:3,15,24
200:14 204:6,15
204:16,17 212:4
229:8 235:21
282:5 290:20
300:19 303:15
319:3 339:2
369:16 400:8
408:17,23 409:3
124:18
tomorrow 34:18
160:2 346:8
tonight 154:4
top 24:24 30:15
72:14 85:13
120:10 124:14
125:16 132:13
133:5 144:17
150:10,12 151:24
158:5 164:12
166:24 190:14
209:17,19,23
234:24 261:19
264:10 265:10
266:5 345:15
351:3 352:24
356:4 367:24,25
369:4 392:15,21
398:5 404:17
405:9
topless 29:25 404:9
tossed 211:15
total 26:25 76:8
135:9 146:12
177:3 236:4
totally 95:9 135:4
207:16 230:8
touch 258:24 375:2
401:10
touched 52:15
86:21
touching 52:14,15
53:9 229:20
towel 86:16 194:10
town 103:23 108:15
111:5 112:3,6
114:2,7,23 232:2
232:23 234:10,16
339:17 372:4,5,11
townhouse 103:25
342:20
toy 71:2 242:20,22
242:24
toys 69:25 70:7,12
70:17,21,22 71:8
71:9 73:22 74:4
75:3 241:22 242:4
242:11,12,13,25
243:8,13
track 314:18
318:17
trafficking 20:6
21:22 335:13
train 81:21 82:2
156:21 157:14,16
276:18
trained 157:9
training 157:5
111:12,18
236:9,11,12
transaction 104:5
382:3
transcript 5:5
71:17,22 72:6
414:15 416:16
transcription 417:4
transcripts 72:8
transportation
275:22 276:7,17
277:4,21 278:7,19
279:4,14,23 280:9
trap 94:19 245:7
trapped 94:20
travel 38:17 48:12
60:22 65:21
108:20 136:25
147:4,11 263:22
263:22 264:3,4,17
267:24 279:19
293:15 401:11,15
410:21,25 411:9
411:13
traveled 43:21
48:11 105:6
208:25 211:9,20
212:17 263:20
401:12,13
traveling 105:25
109:14 147:17
265:23 267:14
268:8 306:7
378:11 387:3,9,11
treated 210:20
trial 403:5
tricky 91:21
tried 25:14 383:16
trip 108:19 109:3,8
109:12,18 131:12
132:20 138:17,22
138:23,25 139:9
139:15 140:14
141:18,20 144:3
145:14 146:11,12
146:13,15,15,20
147:3,5 231:10
233:19 258:22
265:15 266:25
267:7,13 268:16
411:20,23
trips 146:16,23
387:19
trouble 185:25
true 26:12 39:9
80:8 91:2 108:7
177:8 197:24
198:2,4,12 204:14
206:3 210:11
211:18 215:3,3




Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 460 of 465
Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 461 of 465
Page 43
26:14 33:3,20
36:23 53:15,16
57:24 58:6,10
65:9,9 68:5,6,11
68:13,18,23 75:14
75:19,22 76:4,7
77:11,15,20,25
79:7,13,14,15,22
80:3,22 81:10,18
81:21 82:2 87:24
88:2 90:25 105:13
105:14 106:5,12
106:12 108:4,12
108:14,20 111:4,8
111:13,23 114:23
115:4,7,24 116:21
117:2,4 120:18
121:8 122:17
123:23 124:21,22
125:23 126:2,24
127:6,13 132:15
132:22 133:3
135:3,5 143:16
144:7,9 145:19
146:22 171:24
174:12,20,25
175:4,13 176:7,7
176:9,12,14,17
177:2,11,12,22,23
177:25 178:16,17
179:24,24 180:4
182:4,5,13,17
183:4,5,16,20,23
193:21 194:3,7
195:19 196:4,13
196:16,19,20,22
196:25 197:9,15
197:23 198:19,25
199:19 200:16,25
200:25 201:10,19
202:6,12,18,18
203:2,2,10,10,20
203:20 204:7
207:2 208:18,25
210:7,10 211:9,20
218:2 224:4
225:23 226:23
227:17,22 229:17
229:19,21 230:5
232:11,12 233:25
234:3 236:17,25
237:6,23 240:6
241:7 242:8
250:20 251:9,12
254:9,15 256:18
256:22 257:5,12
257:18 258:17
260:19 262:11,16
263:6 265:15,23
267:16 268:10
275:4 280:21
281:4,16,23
282:13 283:23
284:12,19,25
285:13,20 290:10
290:17,21 293:3
297:23 298:16,17
300:2,11 302:2,8
302:14,21 303:11
303:17 304:15
344:4,8,11,16,21
345:5 346:24
352:6 355:2
361:11,22,24
362:7,25 383:19
383:22 384:10,20
387:3,9 399:6,15
399:18,22 404:24
405:2 406:9,19
407:4,10,17
virginias 18:8 30:5
31:2 69:22 89:20
90:10,11,13
104:18 107:2
171:21 175:5
182:6 183:13
204:3 212:6 232:8
235:3 241:14
273:18 303:25
351:6,13,14,17,19
351:24 352:12,14
visa 45:14,19 46:2
visas 100:6,9
visit 17:9 31:22
80:24 112:10
115:10,16 116:8
163:25 247:7
293:16 312:2
328:6
visited 17:7 115:21
115:23 116:3
134:2 409:15
visiting 84:18
112:13 115:18
visits 31:25 32:17
246:13,25
voice 405:23
vowel 363:23 364:3
vr 145:3,10 348:25
350:3,11 405:21
405:23
W
w 4:6 168:6
wages 60:18
wait 7:19
waiver 286:7,7
walk 17:24 18:10
walked 219:17
walking 49:2
wall 234:15,19
want 6:16 11:7
23:10 36:21 53:13
86:2 125:15
128:10 132:3
133:22 138:12
141:11 142:20
148:4,5,9 150:4,9
171:2 177:9,24
179:14 181:17
195:5 200:11,13
222:22 223:2
230:24 231:15
234:5 238:13
248:6 250:14
251:6 257:2,3
278:15 288:9
309:4 318:8
322:17 334:11
337:23 338:4,6
346:15 352:22
361:14,19 363:18
364:2,25 370:16
370:23 373:5
390:4
wanted 8:14,20
15:12 77:16 79:9
219:23 247:10
257:4 314:10
315:11 338:22
339:2,5 345:21
357:16 359:9
364:9 373:4
wants 6:25 7:10
154:3
warrant 186:7,11
186:15,16 188:20
wasnt 78:5,7,8
81:16 153:7
211:17 214:23,23
217:2,6,13,14,15
217:22 218:23
282:20 305:11
314:24 331:23
354:9 355:23
watch 29:19 334:20
way 8:11 11:2
28:14 32:14 68:14
89:18 97:7 142:17
157:19 163:23
183:7 193:4
201:23 218:15
221:25 222:17
227:9 253:24
272:14 291:24
321:20 335:4,10
344:25 352:16
364:14 402:4
404:13
ways 322:13
wear 68:19,23
117:6,13
wearing 86:17
weary 4:25
wedding 377:2,11
377:13
week 161:23 296:4
weeks 377:3,4,7
weissing 2:8
went 32:15 132:20
134:12 140:19
141:20 148:11
173:10,17,20,24
175:8 197:3,10
212:21 227:9
235:22,24 257:18
257:20,21 258:8
258:18,21 298:22
307:24 311:16,19
311:20,23,25
312:6,8 348:11
374:16,25 376:3
376:17
west 19:11 29:8
weve 65:12 144:22
192:8 246:20
249:15 254:14
259:20 299:19
383:21 402:11
117:6,13
314:11 380:22,22
381:3,21 403:9,24
404:7
379:5
whats 36:24 58:17
102:17 149:11
211:13 213:4
215:3 242:19
243:6 259:21
306:20 328:14
340:22 348:3
384:23
whatsoever 109:17
232:21 236:8
247:22 258:24
whilst 8:18 12:6
229:5 277:8
white 141:9,14
whos 277:16
wide 66:23



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 462 of 465
Page 44
willing 310:23
withdraw 357:25
withdrawing 358:3
withheld 286:16
witness 4:7 15:17
21:19 23:5,12
44:2 54:16 74:10
83:12 106:7 119:4
119:7 178:11
181:2 235:18
259:13,16 265:2
320:15 323:22
334:14 335:20
358:6,17 380:5
386:10,23 413:4
416:5,8
witnessed 55:12
witnesses 336:5
witnessing 145:21
woman 10:4 31:25
189:23 220:13
246:9,12 275:22
278:19 280:10
324:25
women 9:18 27:17
116:14 190:8
191:15 276:7,18
277:4,22 278:7
279:4,14,23
370:20 401:20
wonderful 60:23
wondering 149:22
358:24
wont 94:15 96:3
179:5
wood 234:24
word 95:10 97:10
97:11,14 222:12
222:15,19,21,24
247:20 248:6
249:8,8 363:22
382:22,25
words 4:19 5:3 30:2
96:10 98:12
128:20 138:19
139:5 215:2,18
226:3 274:5,18
275:5 293:22
321:24 359:25
work 6:4 8:24 9:16
9:20,23 10:2,7,10
10:12,22 12:23
29:18 41:12,22
47:20 50:5,17,18
59:12 60:25 67:9
101:11,20 102:9
103:11 105:15
116:15 137:17
146:12,15,17,23
147:5 148:11
150:21 152:7
162:10,15 188:6
233:9 245:14
247:21 248:9
272:3 310:9 311:7
311:10 312:3
370:13 382:17
397:6 409:13
412:2,8
worked 48:6 49:25
63:22 72:3 77:12
84:13 88:5 104:2
146:25 187:7
213:12,14,18
225:16,22,24
247:14 248:18
249:6 255:3,21
256:3 271:14
307:10 313:14
316:14 317:6,17
329:6 347:5
374:17,19 404:5
408:17,23 409:5
409:20 412:21
working 10:9,22
29:2 34:16 35:2
50:11 52:13 66:14
75:7 81:8 84:12
84:16 87:22 89:12
90:3,18 92:2
98:11,20 101:16
103:23 104:7
105:13 106:5
116:20 148:25
215:5 218:7,25
219:20 317:10
320:5 322:3
327:16 346:6
348:14 360:15
368:20 381:12
382:15 388:7
396:25 397:2
405:19 407:24
works 137:17
224:20 272:19
world 97:3 210:16
230:16 276:23,25
worry 117:16
wouldnt 28:19
38:19 71:9 78:12
108:8 122:8
135:16,19 191:4
191:12 263:4,7
285:18 294:5
296:25 297:2,3
303:12 315:17
324:8 326:21
327:3 378:9,14
402:19
wrap 373:5
write 149:7 151:9
152:15 160:11
360:11
writing 273:24
274:3 386:14
written 35:13
206:20 228:18
wrong 139:20
140:2 145:4
214:16 220:7
330:14 335:17
373:25
wrote 35:9,23 36:4
36:5,9,24 151:13
206:22 368:5
385:3,9,19,19
391:20
X
x 1:4,10 4:6 168:6
414:3,10
Y
yeah 107:9 141:25
271:17 300:25
371:19
year 9:18 11:3
17:10 25:15 33:7
84:21 91:5,13
121:13 122:9
158:22 159:4,11
165:23 167:16,20
186:16 250:16,20
250:23 251:2,2
282:19,21 296:2
379:11 401:16
years 26:22 35:3
37:12,24 38:10
39:5 59:4 84:22
85:24 86:5 89:12
94:25 95:25 96:4
96:5,9 102:3
126:17,21 158:19
167:4,8,14 208:22
229:3 249:2
294:22 305:22
353:18,22,23
374:17 376:3
403:21 411:12
1:3,17,17,21
1:25,25 3:8,12
5:20 79:14,16,20
79:22 80:18,19,20
80:23 91:10 103:6
112:11,14,22,25
113:18,20 134:19
189:18 190:17
248:19 264:12,13
264:19,23 287:17
293:17 381:22,22
389:4 398:7
399:12 411:9
young 220:4 311:17
younger 25:14,18
25:23 26:6 226:8
youngest 12:22
13:4
youre 29:6 129:13
131:19 132:4
138:23 145:6
219:17 221:11
234:19 235:14
285:17 332:5,23
343:13 346:2
youve 20:6 21:13
112:20 175:7
192:4 221:24
224:17 225:24
263:20 288:3
294:20 348:22
389:24 403:12
404:12 409:18
Z
0
00 373:9
000 103:13,16,21
185:12,20,22
233:14,15,22
340:19,24 342:22
343:5,10,18
371:25
0001 398:6
000109 72:24
0002 399:11
00040 85:9,11
000424 141:15
00068 209:15,19
00071 352:21,25
000744 119:22
000746 131:18
141:20,23
000747 144:16
000759 129:9
000767 266:15,18
00088 356:3
000919 265:9
001044 361:16
001060 367:25



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 463 of 465
Page 45
00109 34:6,10
345:15
00110 346:16
001454 151:20
001456 158:3
001663 319:18
321:7
003191 259:22
003192 259:22
0034 113:24
00376 264:10 266:5
00407 234:11
00721 118:18
00745 125:15
00759 139:22
01452 164:9
01456 148:21
02 67:22 152:2
03 152:2 153:25
04 1:18 3:10 150:14
158:6 159:24
160:23 164:13
294:14
05 353:21
08 117:23
09 117:25
1
1 3:4 24:20 34:20
83:6,13,13 152:2
153:25 166:25
168:5,10 208:12
263:15 414:13
10 67:22,25 209:13
256:14 273:5
297:17 353:14
361:5 362:22
414:22
100 18:25 51:5
60:21 103:13,18
103:20 137:6
185:12 229:9
230:11
1000 135:8 183:3
228:2,12
10026 1:25
109 72:21 414:16
10th 2:17
11 117:23,25 118:4
164:13 259:11,20
259:22 353:6
355:2 368:2,4
405:8,15 414:23
113 414:17
116 5:24
117 414:18
11th 120:10,13
132:20
12 6:2 34:7,11,11
167:24 263:8,14
345:17 347:14
351:4 379:11
414:24
1200 1:24
13 37:12,23 39:5
165:19,22 208:15
312:14,15 414:25
133 414:19
14 42:20 126:21
345:11,12 352:20
415:3
143 414:20
1454 151:19
1456 151:22
147 414:21
14th 120:11
15 33:6 126:21
158:10 161:9
207:9 251:5
348:17,19 355:2
363:14 368:5
415:4
150 2:17
15cv07433rws 1:7
16 26:22 43:12
85:24 86:5 167:8
167:14,16,20
251:2 273:19
282:19 350:23,24
353:18,20,23,25
411:11 415:5
16th 282:17
17 33:4,19 94:25
95:25 96:4,5
109:2,7 121:13
122:9,13 206:15
208:22 224:10,15
224:21,22 225:9
225:24 226:9,10
226:11 250:7,15
250:20,20,23
251:9 254:15,17
273:21 280:21,23
281:5,17,23 282:7
282:13,19 283:4
283:10 284:12,19
284:25 285:13,20
353:23 355:3
360:25 361:2
383:22 384:11,20
411:11 415:6
18 13:8,11,17 14:2
14:11,19 15:9
22:9,13,17,20
23:8,15,23 25:6
27:9,19,22 28:21
29:7,16 30:19,25
32:3,12,23 33:14
35:3 38:2 43:9
46:10,14 56:11,23
57:7 58:17 64:6
67:25 83:17 95:6
99:11,23 100:7
107:21 116:8
121:21 122:3
153:15 157:6,10
157:12,16 158:18
158:22 159:4,11
161:8 162:21,23
163:3,17 164:7
188:11,12 189:24
189:24 190:4,5,9
190:20 222:6
224:5 225:3
246:19 247:15
248:2,8,20 249:14
249:19,25 250:5
250:12 275:23
276:8,19,20 277:4
277:22 278:8,20
279:5,14,24
280:10 325:17
339:9,13 353:19
354:3 363:12
379:18,23 380:6
380:15 382:7,17
383:5,14,15,20
384:2,16 387:12
401:21 402:6,8,15
402:22 411:11
415:7
19 72:17,21,22
365:23 415:8
1961 6:2
1990s 412:16
1991 101:4,10,13
294:19
1992 10:6,10 11:20
11:25 12:7 21:7
96:18,20 101:16
101:19 410:14
1994 403:10
1995 403:10
1999 123:11 340:18
341:2 365:9
2
2 33:25 34:4 68:3
153:25 158:6
208:15 209:20
256:11 361:12
362:24 399:4,23
414:14
20 296:24 297:15
367:21,22 415:9
200 25:11 51:5
60:21 103:21
2000 17:10 96:7
120:10 121:4
282:16,22 342:15
403:21
2000s 410:18
412:16
2001 66:15 101:24
112:15 125:17
126:17 131:24
144:17 342:15
343:7,14 388:6
2002 10:12,21
66:15 105:9 106:3
129:10 139:25
256:19 258:10,17
261:15,22 266:6
266:20 267:2,8
270:12 271:15
272:21 342:15
343:7,14 365:9
366:9,22 367:9,16
403:21 410:19
2003 10:12,21
155:13,21 156:2,3
187:14,14,19
188:15,16 189:9
270:12 271:15
272:21 410:20
2004 85:2,4 91:6,13
313:7 320:2
327:15 328:3,10
328:17,21 333:13
2005 84:23,25
123:11 166:8,12
166:25 313:7
320:2 327:15
328:3,8 333:13
396:15
2006 396:15
2008 11:3
2009 11:3,25 21:7
84:13 96:19,20
185:9 373:12
394:5,18,22
410:16
2011 34:7,11 35:15
35:16,24,25
345:17 347:14
348:6,7,11 353:6
353:14 356:5
357:22 359:4
2014 296:10,14,22
297:11 298:9



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 464 of 465
Page 46
2015 201:9,19
202:5 209:20
273:8,13 297:20
348:18,23 351:4
361:5,12,24
362:24 363:15
365:4,6,7 366:2,6
366:21 368:2
369:25 370:6,12
384:25 390:23
398:7,23 399:3,4
399:19,23 405:9
405:15
2016 1:18 3:9
416:12 417:12
209 414:22
21 168:5,10 384:21
384:24,25 390:23
391:19,22 415:10
21st 266:20 267:9
22 1:18 3:9 129:13
130:20 139:23
390:19,21 415:11
416:12
22nd 125:18 129:13
23 25:15 392:12
415:12
24 348:18,23
353:19,21,21
366:6 398:2,3
414:13 415:13
24th 354:4
25 139:25 150:14
167:24 366:2
405:3,4,7 415:14
259 414:23
25th 140:8
26 118:4 150:3
263 414:24
27 144:20 264:23
266:6 267:21
392:16,18
27th 266:21 267:10
28 24:23 25:7 26:24
275:23 276:8,19
276:20 277:4,22
278:8,20 279:5,15
279:24 280:10
2830 150:6 156:16
2832 157:18,25
2841 159:20
29 144:20
2994 165:11
29th 145:6,8
2nd 155:13
3
3 71:17,20 118:6
167:25 210:7,7
256:14 294:11
353:14 398:6,23
399:3,13 414:15
30 59:3 83:8,16
84:2,7 87:20 88:4
88:9,15,19 89:2,7
89:19 90:6 180:8
180:15 296:10,14
296:22 297:11
298:9
300 42:7 123:10
3008 166:22
30th 127:4
31 144:20
312 414:25
33 414:14
33301 2:5,10
345 415:3
348 415:4,5
361 415:6
363 415:7
365 415:8
367 415:9
370 334:11
375 263:15
383 2:14
384 415:10
39 85:8 327:7
390 415:11
392 415:12
398 415:13
4
4 34:8,11,23,24
109:20,23 150:14
168:11 294:14
327:7,10 414:7,16
40 10:5
400 42:10
401 2:4
405 415:14
425 2:10
43 413:19,20
44 120:5
457 264:12
49 373:6
4th 264:12
5
5 113:21 132:2,2
158:6 208:16
233:14,15,22
373:6 414:17
50 10:5 114:20
297:4 340:19,24
342:22 343:5,10
343:18 371:25
374:17 376:3
500 103:16,18
185:20,21,22
51 294:11
5203106 259:2,25
54 9:18 96:9 327:10
56 208:12
575 1:16 3:11
58 256:11
5th 132:13,19
6
6 117:19 166:25
256:15 263:15
266:12 373:9
413:19,20 414:18
65th 5:24
6th 132:19
7
7 60:19 133:4,6
159:24 160:23
263:15 294:16
414:19
70 352:23
70s 58:25
71 414:15
744 120:6
746 128:4
76 72:5,11,14 73:3
73:11
794 353:21
8
8 60:19 143:4,10
164:13 263:15
327:12 356:5
414:20
80 263:15
80203 2:18
80s 59:2 376:12
408:11
84112 2:14
89 376:8,8
8th 132:19
9
9 1:18 3:10 60:19
147:23,25 159:24
160:23 263:15
368:5 414:21
90s 91:25 295:14
376:12 381:13
403:20,20,22
404:4 410:17
91 319:17 321:7
917 259:2,25
919 263:16
920 263:16
921 263:16
922 263:16
923 263:16
924 263:16
925 263:16
926 263:17
98 104:12
99 104:12 188:16
366:9,22 367:9,16
9th 132:19



Case 1:15-cv-07433-LAP Document 1137-13 Filed 10/22/20 Page 465 of 465