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