gov.uscourts.nysd.447706.1201.19.pdf

Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 1 of 106 COMPOSITE EXHIBIT 1 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 2 of 106 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 1201-19 Filed 01/27/21 Page 3 of 106 Page 2 Page 4 1 1 G Maxwell - Confidential 2 APPEARANCES: 3 2 represent Ms. Giuffre. BOIES SCHILLER & FLEXNER, LLP 3 MR. PAGLIUCA: Jeff Pagliuca and 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 4 Laura Menninger on behalf of Ms. 5 Fort Lauderdatle, Florida, 33301 5 Maxwell. BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE 6 G H I S L A I N E M A X W E L L, called EMMA ROSEN, PARALEGAL 7 as a witness, having been duly sworn by a 7 8 8 Notary Public, was examined and testified as FARMER JAFFE WEISSING EDWARDS FISTOS & 9 follows: 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 EXAMINATION BY 10 425 N. Andrews Avenue 11 MS. McCAWLEY: Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 Q. Good morning. I'm going to explain 12 13 some of the rules that will happen with 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 respect to depositions. 14 383 South University Street 15 Have you ever been deposed before? Salt Lake City, Utah 84112 15 16 A. I have not. 16 17 Q. What is going to happen here, we HADDON MORGAN FOREMAN 17 Attorneys for Defendant 18 have a court reporter and a videographer. 150 East 10th Avenu 19 What they do is take down the words that we 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 20 say so when I ask you a question they will 19 LAURA A. MENNINGER, ESQUIRE 21 record what you say in response to that. So 20 21 Also Present: 22 we have to be mindful that in order for them 22 James Christe, videographer 23 to do their job we can't talk over each 23 24 24 other. 25 25 Another issue you have to be weary Page 3 Page 5 1 1 G Maxwell - Confidential 2 THE VIDEOGRAPHER: We are now on 2 of is that in a response, you can't give a 3 the record and recording. This begins 3 nonverbal response, in other words, nodding a 4 disk No. 1 in the deposition of 4 yes or no, they need to hear verbal response 5 Ghislaine Maxwell in the matter of 5 so they can record it on their transcript. 6 Virginia Giuffre versus Ghislaine 6 So that's important for you to remember as we 7 Maxwell in the U.S. District Court for 7 go through the day. If you forget, I will be 8 the Southern District of New York. 8 sure to remind you. 9 Today is April 22, 2016 the time is 9 Is there anything that would 10 9:04 a.m.. This deposition is being 10 prevent you from giving truthful testimony 11 taken at 575 Lexington Avenue in New 11 today? 12 York at the request of Sigrid McCawley 12 A. There is not. 13 of Boies Schiller & Flexner. 13 Q. You are not on any medications or 14 The videographer is James Christe 14 anything that would inhibit your ability to 15 and the court reporter is Leslie Fagin. 15 remember or give truthful testimony? 16 Will counsel state their appearance and 16 A. I am not. 17 whom they represent and then court 17 MR. PAGLIUCA: Could you identify 18 reporter swear in Ms. Maxwell. 18 the assistant in the room. 19 MS. McCAWLEY: My name is Sigrid 19 MS. McCAWLEY: This is Emma Rosen 20 McCawley with my colleague Meredith 20 from our New York office. She is a 21 Schultz. We are with Boies Schiller & 21 paralegal. 22 Flexner. We represent Ms. Giuffre. 22 Q. Ms. Maxwell, can you please state 23 MR. EDWARDS: Brad Edwards. I also 23 your address for the record? 24 represent Ms. Giuffre. 24 A. Currently . 25 MR. CASSELL: Paul Cassell, I also 25 Q. What is your date of birth? 2 (Pages 2 to 5) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 4 of 106 Page 6 Page 8 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 A. 2 It's in the process of being sold. It still 3 Q. When did you first recruit a female 3 requires some final paperwork to be done, so 4 to work for Mr. Epstein? 4 just for the purposes of clarity. 5 MR. PAGLIUCA: I object to the form 5 Q. Do you have a new address where you 6 and foundation of the question. I 6 will be living? 7 believe this is confidential 7 A. I do not. 8 information. I ask anyone who is not 8 Q. For the purpose of the record, if 9 admitted in this case be excused from 9 there is something I ask you that you later 10 the room, please. 10 remember something else or need to correct 11 MS. McCAWLEY: So the response to 11 your testimony in some way, you can do that, 12 that question would -- 12 just let me know what it is and we will go 13 MR. PAGLIUCA: The subject matter 13 back to that question and can you clarify. 14 of this question is confidential and I'm 14 A. Of course. I just wanted to be 15 designating it as confidential. 15 clear, there is still some paperwork pending 16 MS. McCAWLEY: I just want to make 16 for final release, but it's in the process of 17 that clear for the record. 17 sale. But I don't have another address 18 MR. EDWARDS: So we don't delay the 18 currently, so whilst that should still be of 19 deposition I will step out of the room 19 record that the mail could be forwarded 20 but I think it's important to lay the 20 there, so for purposes of clarity I wanted to 21 record that -- 21 be clear. 22 MR. PAGLIUCA: I'm sorry, you are 22 Q. I appreciate that. 23 not admitted in this proceeding so you 23 So Ms. Maxwell, when did you first 24 are not entitled to make any record. If 24 recruit a female to work for Mr. Epstein? 25 Ms. McCawley wants to make a record she 25 MR. PAGLIUCA: Again. I object to Page 7 Page 9 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 can. 2 form and foundation of the question. 3 MR. EDWARDS: I can make a record 3 Q. You can answer the question. 4 right now. 4 A. First of all, can you please 5 MR. PAGLIUCA: Maybe we should get 5 clarify the question. I don't understand 6 the judge on the phone and talk about 6 what you mean by female, I don't understand 7 it. 7 what you mean by recruit. Please be more 8 MR. EDWARDS: The record will be 8 clear and specific about what you are 9 short. This is the precise reason why 9 suggesting. 10 Ms. Giuffre wants me in this case and 10 Q. Are you a female, is that the sex 11 I'm unable to effectively represent her 11 that you are? 12 at this time because I am unable to have 12 A. I am a female. 13 access to the confidential information 13 Q. That's what I'm referring to a 14 which includes apparently the entire 14 female and I'm asking you when you first, the 15 deposition of Ms. Maxwell. But for the 15 very first time you recruited a female to 16 sake of not further delaying this, I 16 work for Mr. Epstein? 17 will be outside the room. 17 A. Again, I don't understand what 18 MS. McCAWLEY: Thank you. 18 female -- I am a 54 year old women. 19 A. I would like to just -- wait for 19 Q. I'm not making it age, any age of a 20 him to leave. 20 female that you recruited to work for Mr. 21 Q. That's fine. 21 Epstein? 22 A. I would just like to clarify the 22 A. Again, I was somebody who hired a 23 address. I'm in the process of selling the 23 number of people to work for Mr. Epstein and 24 house so while while I still receive mail 24 hiring is one of my functions. 25 there, it's not my actual physical address. 25 Q. And when is the first time you 3 (Pages 6 to 9) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 5 of 106 Page 10 Page 12 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 2 MR. PAGLIUCA: Object to the form 3 female? 3 and foundation. 4 A. As best as I can recollect, a woman 4 A. My job entailed running the homes 5 the age probably of about 40 or 50 was in 5 that he had but much more importantly, most 6 sometime in 1992. 6 of the houses had construction and so whilst 7 Q. How long did you work for Mr. 7 in 1992 there was no construction project, 8 Epstein? 8 there was construction projects that began 9 A. I started working for him at some 9 after that time and I was in charge not only 10 point in 1992 and the nature of my work 10 of hiring architects, I was also in charge of 11 relationship with him changed over time so 11 all the filings or overseeing that, like a 12 from around 2002, 2003, the work lessened 12 general contractor would. 13 considerably. 13 I also helped with hiring the 14 Q. When did you -- 14 architects, hiring the builders, reviewing 15 MR. PAGLIUCA: Can I interject for 15 the contracts for the builders, coordinating 16 a moment. If we are talking about 16 the building projects, coordinating how the 17 background -- 17 projects would layout, the timing of the 18 MS. McCAWLEY: I'm in the middle of 18 projects and all the various materials that 19 a question. Let me finish it and then 19 they would require to run a very substantial 20 can you interject. 20 building project. That's the nature of the 21 Q. When you say 2002 to 2003 that the 21 job I was dealing with. 22 work lessened, when did you complete working 22 Q. How old was the youngest female you 23 for Mr. Epstein; when was the last time you 23 ever hired to work for Jeffrey? 24 were employed by him, the last date? 24 MR. PAGLIUCA: Object to the form 25 A. I believe I still was doing -- 25 and foundation. Page 11 Page 13 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 2 Q. You can answer. 3 hour or two a year at sometime 2008 and 2009. 3 A. I have not any idea exactly of the 4 MR. PAGLIUCA: So if you are going 4 youngest adult employee that I hired for 5 to be talking about general background, 5 Jeffrey. 6 I don't need to designate that as 6 Q. When you say adult employee, did 7 confidential. So if you want to have 7 you ever hire someone that was under the age 8 them come back in, that's fine. 8 of 18? 9 I assumed by your first question 9 A. Never. 10 you were going into more sensitive 10 Q. Did you ever bring someone who was 11 areas. I will leave it up to you, but 11 under -- invite someone under the age of 18 12 if this is general background it will 12 to Jeffrey's home, any of his homes? 13 not be designated as confidential. 13 MR. PAGLIUCA: Object to the form 14 MS. McCAWLEY: I appreciate that. 14 foundation. 15 I will jump back into my other 15 A. Can you repeat the question? 16 questions. 16 Q. Did you ever invite anybody who was 17 MR. PAGLIUCA: So we will keep it 17 under the age of 18 to Jeffrey's homes? 18 as confidential. 18 MR. PAGLIUCA: Same objections. 19 Q. When you were first employed by him 19 A. I have a number of friends that 20 in 1992, what were you hired to do? 20 have children and friends of mine that have 21 A. First, I was consulting and what I 21 kids and in the invitation of my friends and 22 did was I helped with decorating houses and 22 their kids, I'm sure I may have invited some 23 in hiring staff to help run those houses. 23 of my friend's kids to come. 24 Q. Did your duties change over the 24 Q. Anybody that is not a friend of 25 course of 1992 to 2009? 25 yours. 4 (Pages 10 to 13) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 6 of 106 Page 14 Page 16 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Any female under the age of 18, did 2 A. Ms. Roberts held herself out -- 3 you invite them to come to Jeffrey's home? 3 Q. I'm not asking how she held herself 4 MR. PAGLIUCA: Object to the form 4 out. I'm asking how she arrived at the home. 5 and foundation. 5 Did you meet her and invite her to come to 6 A. Again, as I said, I am not aware of 6 the home or how did she arrive there? 7 inviting anybody other than friends of mine 7 MR. PAGLIUCA: Object to the form 8 who have children to the house. 8 and foundation. 9 Q. Did you invite Virginia Giuffre to 9 A. Ms. Roberts held her to be a 10 come to Jeffrey Epstein's home when she was 10 masseuse and her mother drove her to the 11 under the age of 18? 11 house. 12 MR. PAGLIUCA: Object to the form 12 Q. When did you first meet Virginia 13 and foundation. 13 Roberts? 14 A. Virginia Roberts held herself out 14 A. I don't have a recollection of the 15 as a masseuse and invited herself to come and 15 first meeting. 16 give a massage. 16 Q. Do you recall meeting her at 17 Q. My question is, did you invite 17 Mar-a-Lago? 18 Virginia Roberts when she was under the age 18 A. Like I said, I don't have a 19 of 18 to come to Jeffrey Epstein's home? 19 recollection of meeting Ms. Roberts. 20 MR. PAGLIUCA: Object to the form 20 Q. So you recall Ms. Roberts being 21 and foundation. 21 brought to the home by her mother, is that 22 A. Again, Virginia Roberts was a 22 your testimony? 23 masseuse -- 23 A. That is my testimony. 24 Q. I'm asking not asking if she was a 24 Q. And that is the first time you met 25 masseuse. I'm asking if you invited her to 25 her? Page 15 Page 17 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 come to Jeffrey Epstein's home? 2 A. Like I said, I don't recall meeting 3 A. Again, there would be no course to 3 her the first time. I do remember her mother 4 have a conversation with Virginia unless she 4 bringing her to the house. 5 held herself out to be a masseuse. 5 Q. Are you a member at Mar-a-Lago? 6 Q. I'm not asking that question. I'm 6 A. No. 7 asking if you invited her to come to Jeffrey 7 Q. Have you visited Mar-a-Lago? 8 Epstein's home when she was under the age of 8 A. Yes. 9 18? 9 Q. Did you visit Mar-a-Lago in the 10 A. Again, I repeat, she was a masseuse 10 year 2000? 11 and in the form and as my job, I was to have 11 A. I'm pretty sure I did. 12 people who he wanted for various things 12 Q. When Ms. Roberts arrived at the 13 including massage. She came as a masseuse. 13 home with her mother, what happened? 14 Q. So you invited her to his home to 14 A. I spoke to her mother outside of 15 come to give a massage, is that correct? 15 the house and she -- what I don't recall is 16 MR. PAGLIUCA: Object to the form 16 exactly what happened because I was talking 17 and foundation. Misstates the witness' 17 to her mother the entire she was in the 18 testimony. 18 house. 19 A. Again, I did not invite Virginia 19 Q. Did you introduce Ms. Roberts to 20 Roberts. She came as a masseuse. 20 Jeffrey Epstein? 21 Q. She who invited her to come as a 21 A. I don't recall how she actually met 22 masseuse, she just showed up at the front 22 Mr. Epstein. As I said, I spoke to her 23 door? 23 mother the entire time outside the house. 24 MR. PAGLIUCA: Object to the form 24 Q. Did you walk Ms. Roberts up to the 25 and foundation. 25 upstairs location at the Palm Beach house to 5 (Pages 14 to 17) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 7 of 106 Page 18 Page 20 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 meet Mr. Epstein? 2 you not to answer that question. I 3 MR. PAGLIUCA: Object to the form 3 don't have any problem with you asking 4 and foundation. 4 questions about what the subject matter 5 Q. You can answer. 5 of this lawsuit is, which would be, as 6 A. I just explained. 6 you've termed it, sexual trafficking of 7 A. I spent the entire time talking to 7 Ms. Roberts. 8 Virginia's mother outside the house so the 8 To the extent you are asking for 9 answer to the question is no. 9 information relating to any consensual 10 Q. No, did you not walk her up and 10 adult interaction between my client and 11 introduce her to Mr. Epstein? 11 Mr. Epstein, I'm going to instruct her 12 A. I just said no. 12 not to answer because it's not part of 13 Q. Did you participate in a massage 13 this litigation and it is her private 14 this first time when she first came to the 14 confidential information, not subject to 15 home and you were speaking with her mother, 15 this deposition. 16 she was in the home, is that correct, you 16 MS. McCAWLEY: You can instruct her 17 brought her into the home? 17 not to answer. That is your right. But 18 MR. PAGLIUCA: Object to the form 18 I will bring her back for another 19 and foundation. 19 deposition because it is part of the 20 A. I will repeat again, I was standing 20 subject matter of this litigation so she 21 outside with her mother so very difficult for 21 should be answering these questions. 22 me to do anything else at that time so no, I 22 This is civil litigation, deposition and 23 did not take her upstairs. 23 she should be responsible for answering 24 Q. Did you participate -- 24 these questions. 25 A. Virginia lied 100 percent about 25 MR. PAGLIUCA: I disagree and you Page 19 Page 21 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 absolutely everything that took place in that 2 understand the bounds that I put on it. 3 first meeting. She has lied repeatedly, 3 MS. McCAWLEY: No, I don't. I will 4 often and is just an awful fantasist. So 4 continue to ask my questions and you can 5 very difficult for anything to take place 5 continue to make your objections. 6 that she repeated because I was with her 6 Q. Did you ever participate from the 7 mother the entire time. 7 time period of 1992 to 2009, did you ever 8 Q. So did you have -- did you give a 8 participate in a massage with Jeffrey Epstein 9 massage with Virginia Roberts and Mr. Epstein 9 and another female? 10 during the first time Virginia Roberts was at 10 MR. PAGLIUCA: Objection. Do not 11 the West Palm Beach house? 11 answer that question. Again, to the 12 MR. PAGLIUCA: Object to the form 12 extent you are asking for some sort of 13 and foundation. 13 illegal activity as you've construed in 14 Q. Yes or no? 14 connection with this case I don't have 15 A. No. 15 any problem with you asking that 16 Q. Have you ever given a massage with 16 question. To the extent these questions 17 Virginia Roberts in the room and Jeffrey 17 involve consensual acts between adults, 18 Epstein? 18 frankly, they're none of your business 19 MR. PAGLIUCA: Object to the form 19 and I will instruct the witness not to 20 and foundation. 20 answer. 21 A. No. 21 MS. McCAWLEY: This case involves 22 Q. Have you ever given Jeffrey Epstein 22 sexual trafficking, sexual abuse, 23 a massage? 23 questions about her having interactions 24 MR. PAGLIUCA: Object to the form, 24 with other females is relevant to this 25 foundation. And I'm going to instruct 25 case. She needs to answer these 6 (Pages 18 to 21) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 8 of 106 Page 22 Page 24 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 questions. 2 MR. PAGLIUCA: Object to the form 3 MR. PAGLIUCA: I'm instructing her 3 and foundation. 4 not to answer. 4 A. How would I possibly know how 5 MS. McCAWLEY: Then we will be back 5 someone is when they are at his house. You 6 here again. 6 are asking me to do that. I cannot possibly 7 Q. Have you ever given a massage to 7 testify to that. As far as I'm concerned, 8 Mr. Epstein with a female that was under the 8 everyone who came to his house was an adult 9 age of 18? 9 professional person. 10 A. Can you repeat the question? 10 Q. Are you familiar with the police 11 Q. Yes. Have you ever given a massage 11 report that was issued in respect to the 12 to Mr. Epstein with a female that was under 12 investigation in this matter? 13 the age of 18? 13 MR. PAGLIUCA: Object to the form 14 A. No. 14 and foundation. 15 Q. Have you ever observed Mr. Epstein 15 Q. Are you familiar with the police 16 having a massage given by an individual, a 16 report that was used in this matter, the 17 female, who was under the age of 18? 17 investigation of Jeffrey Epstein, has been 18 A. No. 18 produced as a document in this matter? 19 Q. Have you ever observed females 19 A. I have seen a police report. 20 under the age of 18 in the presence of 20 (Maxwell Exhibit 1, police report, 21 Jeffrey Epstein at his home? 21 marked for identification.) 22 MR. PAGLIUCA: Object to the form 22 Q. The police report that you have in 23 and foundation. 23 front of you, can you turn to page 28 of that 24 A. Again, I have friends that have 24 report, the numbers are on the top right-hand 25 children -- 25 corner. Page 23 Page 25 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 2 You will see some redactions in 3 talking about individuals -- 3 this report, Ms. Maxwell, the redacted 4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals 5 to you interrupting the witness who was 5 the name of a minor, someone who is under the 6 answering your question. The question 6 age of 18. 7 was, have you ever seen anyone, female 7 On page 28, in the third paragraph, 8 under the age of 18 at the house and 8 about halfway down, it says, stated 9 that's the question she was answering. 9 she performed the massage naked. At the 10 If you want to strike that question and 10 conclusion of this massage, Epstein paid 11 ask another question, feel free, but let 11 $200 for the massage. He explained, I 12 the witness respond, please. 12 know you are not comfortable put I will pay 13 MS. McCAWLEY: I will do that. 13 you if you bring some girls. He told her the 14 Q. Have you ever observed a female 14 younger the better. stated once tried 15 under the age of 18 at Jeffrey Epstein's home 15 to bring a 23 year old to Epstein and he 16 that was not a friend, a child -- one of your 16 stated the female was too old. 17 friend's children? 17 Have you heard Mr. Epstein use the 18 A. Again, I can't testify to that 18 phrase the younger the better? 19 because I have no idea what you are talking 19 A. I have no recollection of hearing 20 about. 20 that. 21 Q. You have no idea what I'm talking 21 Q. Have you used the phrase in talking 22 about in the sense you never observed a 22 to and asking her to recruit 23 female under the age of 18 at Jeffrey 23 females for Mr. Epstein, the younger the 24 Epstein's home that was not one of your 24 better? 25 friend's children, is that correct? 25 MR. PAGLIUCA: Object to the form 7 (Pages 22 to 25) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 9 of 106 Page 26 Page 28 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 and foundation of the question. 2 A. First of all, as I said when I was 3 A. First of all, can you break the 3 present -- 4 question apart. 4 Q. It is a yes or no. 5 Q. Have you used the phrase the 5 A. No, it is not. 6 younger the better in speaking to 6 Q. You can answer the question in full 7 and asking her to recruit females for Jeffrey 7 but please provide yes or no as an initial 8 Epstein? 8 matter. 9 MR. PAGLIUCA: Object to the form 9 A. I cannot answer yes or no, it's not 10 and foundation. 10 bounded by time. It's entirely possible I 11 Q. You can answer. It's yes or no. 11 could have been in a room or even in the 12 A. No, that's absolutely not true, on 12 vicinity of Palm beach when somebody came and 13 the second part of your question, I have not 13 I would not know. How would I know when 14 asked Virginia to recruit females and the 14 somebody was in the house. There is no way I 15 first part of your question, if you can 15 can know. 16 repeat that again, the question you asked. 16 Q. Did you stay at Jeffrey Epstein's 17 Q. Will you read back the question. 17 home when you were in Palm Beach? 18 (Record read.) 18 A. Most of the time. 19 A. I believe I answered the later part 19 Q. So how is it that you wouldn't know 20 of the question. The first part of the 20 if there was a female in the home under the 21 question, it's impossible for me to recall 21 age of 18 if you were staying there? 22 events that took place 16 years ago but it 22 A. Well, first of all, when I was 23 doesn't sound like something I would say. 23 staying there, the house is actually quite 24 Q. On page 28, that same paragraph, 24 large and I have a very busy job and I had an 25 was asked how many girls in total she 25 office with a door so the door would be shut Page 27 Page 29 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 brought to Epstein. stated that she 2 and I would be working. I'm not responsible 3 can remember, stated that she brought 3 for what Jeffrey does and I don't always pay 4 and, it's redacted there, and the victim in 4 attention to what happens in the house. I'm 5 this case. 5 very busy. 6 Let me ask my question, I have a 6 Q. So you're testifying that you never 7 question pending right now. 7 observed a female under the age of 18 at 8 Are you testifying that you are 8 Jeffrey Epstein's West Palm Beach home? 9 unaware of any underage, under the age of 18, 9 MR. PAGLIUCA: Object to the form 10 females coming to Jeffrey Epstein's home to 10 and foundation. 11 perform massages? 11 A. I already answered that question, I 12 MR. PAGLIUCA: Object to the form 12 believe. 13 foundation. 13 Q. You didn't answer my question. 14 A. You need to straddle that question 14 A. I did. 15 in a different time period. When I was 15 Q. Did you observe a female under the 16 there, at the time I was present, the people 16 age of 18 at Jeffrey Epstein's home in Palm 17 that gave Jeffrey, men and women who gave 17 Beach? 18 Jeffrey massages were adults over the age of 18 A. Like I said, I work, I don't sit 19 18. 19 there and watch people coming in and out of 20 Q. Never in your time at any of 20 the house. I cannot possibly tell you if I'm 21 Jeffrey Epstein's homes were you present when 21 in the home that somebody was there that I 22 a female under the age of 18 was there to 22 did not see, I cannot comment on it, I have 23 give Jeffrey Epstein a massage? 23 no idea. 24 MR. PAGLIUCA: Object to the form 24 Q. Did you observe females at Jeffrey 25 and foundation. 25 Epstein's home that were laying out topless 8 (Pages 26 to 29) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 10 of 106 Page 30 Page 32 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 in the back of the home, in other words 2 Q. Did you ever hire a masseuse that 3 without a shirt on? 3 was under the age of 18? 4 A. So that's just another of 4 MR. PAGLIUCA: Object to the form 5 Virginia's lies. So let's be clear, at the 5 and foundation. 6 time when I was there and present, frequently 6 Q. Did you? 7 at the house, it was unusual to see people 7 A. Again, I don't hire massage 8 without their clothes on. 8 therapists, so that was not my job. 9 Q. When you say unusual, did you 9 Q. You just said you did, you just 10 observe people without their clothes at 10 said you hired massage therapists for Jeffrey 11 Jeffrey Espstein's home? 11 Epstein, I'm asking if you hired a massage 12 A. Can I answer. Sometimes people in 12 therapist who was under the age of 18? 13 the privacy of a house and swimming pool, I 13 A. Let me correct myself. When I 14 have seen people from time to time take their 14 meant hire, I didn't mean hire in the way you 15 top off. I have seen people from time to 15 are doing it. What I say is that I went to 16 time do that. Very unusual. Naked people 16 spas and I met people and if they did home 17 around the people at any frequent period of 17 visits, Jeffrey would then, in fact, hire 18 time, I have never seen. 18 them. I'm not responsible for hiring 19 Q. Were they under the age of 18? 19 someone. And they were not full-time, so 20 A. As I was saying, people when I was 20 it's not a correct characterization. 21 in the house, were of adult age, if they were 21 Q. Did you ever, your term is meet, 22 children, friends of my family or friends 22 did you ever meet a person that was under the 23 that were there, they may well have been 23 age of 18 that you -- that Jeffrey then hired 24 because I have nieces and nephews under the 24 as a masseuse? 25 age of 18, I cannot testify to anybody else 25 MR. PAGLIUCA: Object to the form Page 31 Page 33 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 2 and foundation. 3 fictitious lies and stories to make this a 3 A. First of all, Virginia Roberts who 4 salacious event to get interest and press. 4 you are referring to was a masseuse aged 17, 5 It's absolute rubbish. 5 we all now know, so your story that you keep 6 Q. Were you in charge of hiring 6 pushing out to the press that she was a 15 7 individuals to provide massages for Jeffrey 7 year old -- you and I both know was a lie, 8 Epstein? 8 correct. 9 A. My job included hiring many people. 9 Q. You are not sentencing my question. 10 There were six homes. As I sit here, I hired 10 A. You and I both know that was a lie, 11 assistants, I hired architects, I hired 11 correct. 12 decorators, I hired cooks, I hired cleaners, 12 Q. You are not answering my question. 13 I hired gardeners, I hired pool people, I 13 I'm asking you whether you ever met a female 14 hired pilots, I hired all sorts of people. 14 under the age of 18 that Jeffrey then hired 15 In the course and a very small part 15 as a masseuse? 16 of my job was from from time to time to find 16 MR. PAGLIUCA: Object to the form 17 adult professional massage therapists for 17 and foundation. 18 Jeffrey. 18 A. The only person I can talk about 19 Q. When you say adult professional 19 who clearly was a massage age 17, a masseuse, 20 massage therapists, where did you find these 20 was Virginia. 21 massage therapists? 21 Q. Did you meet her and then introduce 22 A. From time to time I would visit 22 her to Jeffrey? 23 professional spas, I would receive a massage 23 A. I don't know. I already testified 24 and if the massage was good I would ask that 24 I don't recall meeting her. 25 man or woman if they did home visits. 25 (Maxwell Exhibit 2, email, marked 9 (Pages 30 to 33) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 11 of 106 Page 34 Page 36 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 for identification.) 2 Q. Are you questioning that this 3 Q. So I'm showing you a document that 3 document is incorrect, this document -- this 4 we have marked as Maxwell Exhibit 2. It's a 4 email that you wrote? 5 document you produced in this matter labeled 5 A. I wrote an email. I was trying to 6 confidential GM 00109. It's dated Sunday 6 be accurate, so who knows, with all the 7 June 12, 2011. It's from Jeffrey Epstein to 7 rubbish that you guys have put out in the 8 you. If you can turn to page 4 -- sorry, can 8 press that I read, maybe in the moment I 9 you turn to the first page, the cover page 9 wrote it a memory came to me that I don't 10 initially which is 00109. If you look under 10 know, but as I sit here today and the 11 the time stamp it says, June 12, 2011 at 4:12 11 testimony I gave you today is I don't 12 p.m., it says 12 recollect it. 13 Is that your email address? 13 Q. Does this refresh your recollection 14 A. It is. 14 that you recalled meeting Ms. Roberts at 15 Q. Under that it says, Thank you. I 15 Mar-a-Lago? 16 have it now and I'm working on a letter, a 16 A. It does not. 17 little, I will send the final version 17 Q. So your testimony today is that you 18 tomorrow and what ever it is will be 18 don't remember meeting Ms. Roberts at 19 factually accurate. 19 Mar-a-Lago? 20 Do you see that on page 1? 20 A. I do not. 21 A. I do. 21 I just want to clarify, when you 22 Q. Then I would like you to turn to 22 read so much stuff and so much rubbish that 23 page 4 please. The second paragraph down on 23 comes out from Virginia Roberts, you don't 24 page 4, it states, After some thought, I 24 know what's up and down, at the time I wrote 25 recall that I first met Ms. Roberts when she 25 this I believe I had a memory but as I sit Page 35 Page 37 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 was working at a premier resort claiming to 2 here today I do not. 3 be 18 years old and a professional masseuse? 3 Q. Ms. Maxwell, when did you first 4 MR. PAGLIUCA: What line are you 4 meet 5 on, counsel. 5 MR. PAGLIUCA: Object to the form 6 MS. McCAWLEY: Second paragraph 6 and foundation. 7 down. 7 A. I have no idea when I met her. 8 MR. PAGLIUCA: I got it. 8 Q. Do you know how old she was when 9 Q. Is that a statement that you wrote? 9 you met her? 10 A. It appears to be. 10 A. I have no idea how old she was when 11 Q. So does that correct your testimony 11 I met her. 12 that you did meet Ms. Roberts at Mar-a-Lago? 12 Q. Is it possible she was 13 years old 13 A. Again, this was written in, when 13 when you first met her? 14 were you saying? 14 MR. PAGLIUCA: Object to the form 15 Q. 2011. 15 and foundation. 16 A. So by 2011, Ms. Roberts had already 16 A. 17 perpetrated so many lies and stories it's 18 hard for me to accurately tell you today what 18 may have been in the house when Jeffrey was 19 I remember back then. As I sit here today, 19 in the house. I have no idea how old she 20 the testimony I give you today, I do not 20 was. 21 recollect it. 21 Q. I understand 22 Q. Do you have a reason to say that 22 . 23 this document that you wrote is incorrect? 23 I'm asking if was 13 24 A. It's in 2011, I can't possibly tell 24 years old when you first met her? 25 you what I remember in 2011. 25 A. I have no idea. 10 (Pages 34 to 37) Case 1:15-cv-07433-LAP Document 1201-19 Filed 01/27/21 Page 12 of 106 Page 38 Page 40 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met 2 3 her? 3 MR. PAGLIUCA: Object to the form 4 A. I have no idea how old she was when 4 and foundation. 5 I first met her. 5 Q. Is that your testimony? 6 Q. Did she look like a child when you 6 A. I already said I don't recall all 7 first met her? 7 the times I've seen her and I have no memory 8 A. I don't remember what she looked 8 of that. 9 like at the time she was in the house. 9 Q. Have you ever seen in 10 Q. How many years have you known her? 10 the house with Jeffrey Epstein 11 A. I can only recall the last time I 11 12 saw her. 12 MR. PAGLIUCA: Object to the form 13 Q. When was the first time you met 13 and foundation. 14 her? 14 A. I just told you I don't recall 15 A. Again, I just told you, I don't 15 seeing 16 recall the first time I met her. 16 Q. Were you ever involved in an orgy 17 Q. Did travel with you 17 with 18 on Jeffrey's planes? 18 A. No, absolutely not. 19 A. I wouldn't remember if was on 19 Q. Can you tell me, do you know an 20 the plane or not. 20 individual by the name of 21 Q. Did you ever have sex with 21 A. I do. 22 22 Q. How did you meet 23 A. No. 23 A. At some point she was a friend of 24 Q. Did you ever observe Jeffrey having 24 Jeffrey's and I recall meeting her at some 25 sex with 25 point. Page 39 Page 41 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 A. No. 2 Q. Did you hire her? 3 Q. Were you aware that Jeffrey was 3 A. First of all, I don't hire girls 4 having sexual contact with when 4 like that, so let's be clear, I already 5 she