gov.uscourts.nysd.447706.1320.5.pdf

Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 1 of 56 COMPOSITE EXHIBIT A Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 2 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 3 of 56 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 MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 4 of 56 Questions About People Under the Age of 18 at Epstein’s Home Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 5 of 56 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 6 of 56 Questions About Meeting the Plaintiff and Massages with Plaintiff Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 7 of 56 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? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 8 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 9 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 10 of 56 Questions About Massages with Minors Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 11 of 56 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 -- MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 12 of 56 Questions About Hiring Massage Therapists Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 13 of 56 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 14 of 56 Questions About Jane Doe 2 and Nadia Marcinkova Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 15 of 56 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 19 may have been in the house when Jeffrey was in the house. I have no idea how old she - 20 was. 21 22 23 - Q. I understand she was with I'm asking if - was 13 24 years old when you first met her? 25 A. I have no idea. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 16 of 56 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 20 A. I wouldn't remember if the plane or not. - was on 21 22 23 Q. A. Did you ever have sex with No. - 24 Q. Did you ever observe Jeffrey having 25 sex with MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 17 of 56 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 ■- 12 Q. Were you in the house when was in the house in a private area 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 24 - I don't understand what your question is asking. 25 Q. So you have never seen - MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 18 of 56 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 13 - MR. PAGLIUCA: and foundation. Object to the form 14 A. I just told you I don't recall 15 16 17 seeing with Q.- Were you ever involved in an orgy 18 A. No, absolutely not. 19 Q. Can you tell me, do you know an 20 individual by the name of Nadia Marcinkova? 21 A. I do. 22 Q. How did you meet Nadia Marcinkova? 23 A. At some point she was a friend of 24 Jeffrey's and I recall meeting her at some 25 point. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 19 of 56 Page 46 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 3 Nadia Marcinkova? 4 A. I don't know what Jeffrey did. I 5 cannot testify what Jeffrey did. 6 Q. Was Nadia 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 Nadia 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 Nadia 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 Nadia? 23 A. No. 24 Q. Is she a pilot? 25 A. I have no idea. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 20 of 56 Questions About Mr. Epstein and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 21 of 56 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. MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 22 of 56 Questions About Sarah Kellen, Glen Dubin, Plaintiff, Johanna Sjoberg, Annie Farmer and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 23 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 24 of 56 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 Annie Farmer? 19 A. I am. 20 Q. Has Annie Farmer given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 25 of 56 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 Sarah Kellen 5 did. 6 Q. You never observed Sarah Kellen 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 Glenn Dubin? 13 A. I do. 14 Q. What is your relationship with 15 Glenn Dubin? 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 Eva Dubin. 22 Q. Is Eva Dubin one of your friends? 23 A. Yes. 24 Q. Did you ever send Virginia to 25 Glenn's condo at the Breakers to give him a MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 26 of 56 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 Glenn? 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 Eva Anderson 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, MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 27 of 56 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 Johanna Sjoberg, when 8 did you first meet Johanna? 9 A. I don't recall the exact date. 10 Q. Did you hire Johanna? 11 A. I don't hire people, she came 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 Johanna? 22 A. I don't recall the exact interview, 23 no. 24 Q. Do you know what tasks Johanna was 25 hired to performance? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 28 of 56 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 Johanna that she 11 would get extra money if she provided Jeffrey 12 massages? 13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 around 7, 8, $9 and as a professional 20 healthcare provider you can earn somewhere 21 between as we have established 100 to $200 22 and to be able to travel and have a job that 23 pays that is a wonderful job opportunity. So 24 in the context of advising people for 25 opportunities for work, it is possible that I MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 29 of 56 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 Johanna massage 10 you? 11 A. I did. 12 Q. How many times? 13 A. I don't recall how many times. 14 Q. Was there sex involved? 15 A. No. 16 Q. Did you ever instruct Johanna to 17 massage Glenn Dubin? 18 A. I don't believe -- I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 MR. PAGLIUCA: Object to the form 23 and foundation. You need to give me an 24 opportunity to get in between the 25 questions. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 30 of 56 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 Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 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 Johanna that was not consensual on 16 Johanna's part? 17 MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. I've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 31 of 56 Page 63 1 G Maxwell - Confidential 2 Q. So if Johanna 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 Johanna to Prince 10 Andrew? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I've, again, read that Johanna 14 claimed that she met or that she said she met 15 Prince Andrew. 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 Emmy Taylor? 19 A. I do. 20 Q. How do you know her? 21 A. Emmy was my assistant. 22 Q. So she worked for you? 23 A. Yes. 24 Q. Did you hire her? 25 A. Again, Jeffrey hired people. MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 32 of 56 Questions About Emmy, Virginia, and Ms. Maxwell Regarding Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 33 of 56 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 Emmy, 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 Emmy Taylor 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 34 of 56 Questions About Outfits and Sex Toys Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 35 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 36 of 56 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 37 of 56 Questions About Plaintiff and Epstein and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 38 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 39 of 56 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? MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 40 of 56 Questions About Training Plaintiff to Recruit Girls for Massages Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 41 of 56 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 42 of 56 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 MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 43 of 56 Questions About Ms. Maxwell’s Relationship with Mr. Epstein Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 44 of 56 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. MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 45 of 56 Questions About Recruiting Girls, an Underage Girl in London, and Foreign Girls Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 46 of 56 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 47 of 56 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 Alexander Dixon is? 8 A. I don't recall her right now. 9 Q. Do you know if -- strike that. 10 During the time that you 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 48 of 56 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 Jean Luc Brunel 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of Jean Luc 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 49 of 56 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. MAGNA& LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 50 of 56 Questions About Underage Girls, Sex with Jon Luc Brunel, and Outfits Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 51 of 56 Page 116 1 G Maxwell - Confidential 2 Q. Were you present on the island when 3 Prince Andrew visited? 4 A. Yes. 5 Q. How many times? 6 A. I can only remember once. 7 Q. Were there any girls under the 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 John Luc Brunel? 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 52 of 56 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 Les Wexner? 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 Les Wexner? 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 53 of 56 Questions About Pictures of Naked Girls Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 54 of 56 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 nake