gov.uscourts.nysd.447706.1327.28.pdf

Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 1 of 38 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 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 2 of 38 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) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 3 of 38 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, Roberts 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 RobSON $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. Robson 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 Ms. Roberts 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) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 4 of 38 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 11 12 13 Q. How many years have you known her? A. I can only recall the last time I saw her. Q. When was the first time you met 10 11 12 13 - the house with Jeffrey Epstein MR. PAGLIUCA: Object to the form and foundation. 14 15 16 17 18 19 her? A. Again, I just told you, I don't Q. Did - - recall the first time I met her. on Jeffrey's planes? A. I wouldn't remember if travel with you was on 14 15 16 17 18 19 --A. I just told you I don't recall seeing with . Q. Were you ever involved in an orgy ? A. No, absolutely not. Q. Can you tell me, do you know an 20 the plane or not. 20 individual by the name of Nadia Marcinkova? 21 22 23 24 25 - Q. Did you ever have sex with ? A. No. 1111 Q. Did you ever observe Jeffrey having sex with ? Page 39 21 22 23 24 25 A. I do. Q. How did you meet Nadia Marcinkova? A. At some point she was a friend of Jeffrey's and I recall meeting her at some point. Page 41 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 A. No. 2 Q. Did you hire her? 3 4 5 6 7 8 having sexual contact with she was 13 years old? - Q. Were you aware that Jeffrey was MR. PAGLIUCA: Object to the form and foundation. A. I would be very shocked and when 3 4 5 6 7 8 A. First of all, I don't hire girls like that, so let's be clear, I already testified to that, and I have no idea what you are referring to. Q. When you say girls like that, what do you mean? 9 surprised if that were true. 9 A. I hire people who are professional 10 11 12 13 14 15 - Q. Were you in the house when 1111 was in the house in a private area with Jeffrey Epstein? MR. PAGLIUCA: Object to the form and foundation. A. Can you repeat the question. 10 11 12 13 14 15 at the house. You are asking if I hired somebody to do what, I don't know what you are talking about. I hired people to work in the homes. Q. What was Nadia Marcinkova doing? MR. PAGLIUCA: Object to the form 16 Q. Were you ever in the Palm Beach 16 and foundation. 17 18 19 20 - house when Jeffrey Epstein was in the house with ? MR. PAGLIUCA: Object to the form and foundation. 17 18 19 20 A. I have no idea what Nadia Marcinkova was doing. I didn't hire her and I don't know what you are referring to. Q. You met Nadia Marcinkova? 21 22 23 24 25 - met her and that she was there question is asking. Q. So you have never seen - A. I've already testified that I have I don't understand what your 21 22 23 24 25 A. I testified I did. Q. Did she work for Jeffrey Epstein? A. I have no idea what she did. Q. Have you flown on planes with Nadia Marcinkova? 11 (Pages 38 to 41) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 5 of 38 Page 46 Page 48 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 2 Jeffrey? 3 Nadia Marcinkova? 3 MR. PAGLIUCA: Object to the form 4 A. I don't know what Jeffrey did. I 4 and foundation. 5 cannot testify what Jeffrey did. 5 A. I don't know exactly the nature of 6 Q. Was Nadia involved in sex with 6 her relationship but she worked for him. 7 Jeffrey and other girls? 7 Q. What did she do? 8 MR. PAGLIUCA: Object to the form 8 MR. PAGLIUCA: Object to the form 9 and foundation. 9 and foundation. 10 Q. Girls under the age of 18? 10 A. At the time she when was with him I 11 MR. PAGLIUCA: Same objection. 11 believe she traveled with him and helped with 12 A. I have no idea. 12 his travel arrangements. 13 Q. Was Nadia involved with sex with 13 Q. Did she bring girls to the house to 14 Jeffrey and girls over the age of 18? 14 give massages to Jeffrey? 15 MR. PAGLIUCA: Same objection. 15 MR. PAGLIUCA: Object to the form 16 A. I have no idea. 16 and foundation. 17 Q. Did Nadia recruit other girls for 17 A. I don't know what Sarah did. 18 sex with Jeffrey? 18 Q. So you never observed Sarah 19 MR. PAGLIUCA: Object to the form 19 bringing girls to the home to give massages 20 and foundation. 20 to Jeffrey? 21 A. I have no idea. 21 MR. PAGLIUCA: Object to the form 22 Q. Do you still talk to Nadia? 22 and foundation. 23 A. No. 23 A. I don't understand the question, 24 Q. Is she a pilot? 24 what did you mean bring? 25 A. I have no idea. 25 Q. Did you ever observe Sarah Page 47 Page 49 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. Does she fly with Larry Veseski 2 inviting, bringing, walking anyone into the 3 (phonetic), one of Jeffrey's pilots? 3 home to give a massage for Jeffrey? 4 A. I have no idea. 4 MR. PAGLIUCA: Object to the form 5 Q. Are you a pilot? 5 and foundation. 6 A. I am. 6 A. I don't recollect anything like 7 Q. Have you flown with Jeffrey Veseki? 7 that. 8 A. I have. 8 Q. Are you aware that Sarah Kellen was 9 Q. Have you flown with Nadia 9 a co-conspirator, named as a co-conspirator 10 Marcinkova? 10 in the case involving Jeffrey Epstein? 11 A. What do you mean by flown? 11 MR. PAGLIUCA: Object to the form 12 Q. Have you been on planes with her? 12 and foundation and also calls for a 13 A. I already testified I don't recall 13 legal conclusion. 14 having her on a plane with me. 14 MS. McCAWLEY I'm just asking if she 15 Q. Do you know Sarah Kellen? 15 is aware of that. 16 A. I do. 16 A. I am aware. 17 Q. When did you first meet her? 17 Q. Who paid Sarah Kellen? 18 A. I don't recall exact dates. 18 A. I have no idea. 19 Q. Did you meet her with the purpose 19 Q. Did you ever arrange payment for 20 of hiring her to work for Jeffrey or having 20 any of the employees at the home? 21 Jeffrey hire her? 21 MR. PAGLIUCA: Object to the form. 22 MR. PAGLIUCA: Object to the form 22 A. What do you mean by arrange? 23 and foundation. 23 Q. Were you ever in charge or 24 A. No. 24 responsible for paying individuals at the 25 Q. What was her relationship with 25 home, that worked there? 13 (Pages 46 to 49) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 6 of 38 Page 54 Page 56 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 A. I have. 2 sexual acts on her? 3 Q. No, you haven't. 3 MR. PAGLIUCA: Object to the form 4 A. Yes, I have. 4 and foundation. 5 Q. You are refusing to answer the 5 A. I have not heard that. 6 question. 6 Q. How do you know Annie Farmer? 7 A. Let's move on. 7 A. Annie Farmer had a sister and her 8 Q. I'm in charge of the deposition. I 8 sister introduced Annie Farmer, I believe, to 9 say when we move on and when we don't. 9 Jeffrey. 10 You are here to respond to my 10 Q. Was Annie Farmer under the age of 11 questions. If you are refusing to answer the 11 18? 12 court will bring you back for another 12 MR. PAGLIUCA: Object to the form 13 deposition to answer these questions. 13 and foundation. 14 Do you understand that? 14 A. I don't recall how old Annie Farmer 15 MR. PAGLIUCA: You don't need to 15 was. 16 threaten the witness. 16 Q. Did she tell police that Jeffrey 17 MS. McCAWLEY: I'm not threatening 17 Epstein assaulted her sexually? 18 her. I'm making sure the record is 18 MR. PAGLIUCA: Object to the form 19 clear. 19 and foundation. 20 MR. PAGLIUCA: Certainly can you 20 A. I never heard that. 21 apply to have someone come back and the 21 Q. Did Sarah Kellen recruit or bring 22 court may or may not have her come back 22 girls to the home that were under the age of 23 again. 23 18? 24 Again, she is not answering 24 MR. PAGLIUCA: Object to the form 25 questions that relate to adult consent 25 and foundation and I think this has been Page 55 Page 57 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 sex acts. Period. And that's the 2 asked and answered already. 3 instruction and we can take it up with 3 Q. You can answer the question. 4 the court. 4 A. I have no idea what Sarah Kellen 5 Q. Ms. Maxwell, are you aware of any 5 did. 6 sexual acts with masseuses and Jeffrey 6 Q. You never observed Sarah Kellen 7 Epstein that were nonconsensual? 7 with girls under the age of 18 at Jeffrey's 8 A. No. 8 home? 9 Q. How do you know that? 9 MR. PAGLIUCA: Object to the form 10 A. All the time that I have been in 10 and foundation. 11 the house I have never seen, heard, nor 11 A. The answer is no, I have no idea. 12 witnessed, nor have reported to me that any 12 Q. Do you know Glenn Dubin? 13 activities took place, that people were in 13 A. I do. 14 distress, either reported to me by the staff 14 Q. What is your relationship with 15 or anyone else. I base my answer based on 15 Glenn Dubin? 16 that. 16 MR. PAGLIUCA: Object to the form. 17 Q. Are you familiar with a person by 17 A. What do you mean what is my 18 the name of Annie Farmer? 18 relationship. 19 A. I am. 19 Q. Are you friendly with him, how do 20 Q. Has Annie Farmer given a statement 20 you know him? 21 to police about you performing sexual acts on 21 A. He is the husband of Eva Dubin. 22 her? 22 Q. Is Eva Dubin one of your friends? 23 A. I have not heard that. 23 A. Yes. 24 Q. Has Annie Farmer given a statement 24 Q. Did you ever send Virginia to 25 to police about Jeffrey Epstein performing 25 Glenn's condo at the Breakers to give him a 15 (Pages 54 to 57) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 7 of 38 Page 58 Page 60 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 massage? 2 A. She was tasked to answer 3 MR. PAGLIUCA: Objection to the 3 telephones. 4 form and foundation. 4 Q. Did you ever ask her to rub 5 A. No. 5 Jeffrey's feet? 6 Q. Did you ever instruct Virginia 6 MR. PAGLIUCA: Objection to the 7 Roberts to have sex with Glenn? 7 form and foundation. 8 MR. PAGLIUCA: Objection to the 8 A. I believe that I have read that, 9 form and foundation. 9 but I don't have any memory of it. 10 A. I have never instructed Virginia to 10 Q. Did you ever tell Johanna that she 11 have sex with anybody ever. 11 would get extra money if she provided Jeffrey 12 Q. How old was Eva Anderson when she 12 massages? 13 met Jeffrey? 13 A. I was always happy to give career 14 MR. PAGLIUCA: Objection to the 14 advice to people and I think that becoming 15 form and foundation. 15 somebody in the healthcare profession, either 16 A. I have no idea. 16 exercise instructor or nutritionist or 17 Q. What's she under the age of 18? 17 professional massage therapist is an 18 MR. PAGLIUCA: Objection to the 18 excellent job opportunity. Hourly wages are 19 form and foundation. 19 around 7, 8, $9 and as a professional 20 A. I just testified I have idea how 20 healthcare provider you can earn somewhere 21 old she was. 21 between as we have established 100 to $200 22 Q. You testified she was your friend. 22 and to be able to travel and have a job that 23 You don't know how old she was when she met 23 pays that is a wonderful job opportunity. So 24 Jeffrey? 24 in the context of advising people for 25 A. That happened sometime in the '70s, 25 opportunities for work, it is possible that I Page 59 Page 61 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 how would I know, or '80s. I have no idea. 2 would have said that she should explore that 3 Can you testify to what your friends did 30 3 as an option. 4 years ago? 4 Q. Did you tell her she would get 5 Q. You don't ask the questions here, 5 extra money if she massaged Jeffrey? 6 Ms. Maxwell. 6 A. I'm just saying, I cannot recall 7 What about Johanna Sjoberg, when 7 the exact conversation. I give career advice 8 did you first meet Johanna? 8 and I have done that. 9 A. I don't recall the exact date. 9 Q. Did you ever have Johanna massage 10 Q. Did you hire Johanna? 10 you? 11 A. I don't hire people, she came to 11 A. I did. 12 work at the house to answer phones. 12 Q. How many times? 13 Q. Where did you meet her? 13 A. I don't recall how many times. 14 A. I just testified, I don't recall 14 Q. Was there sex involved? 15 exactly when I met her. 15 A. No. 16 Q. Was one of your job 16 Q. Did you ever instruct Johanna to 17 responsibilities to interview people that 17 massage Glenn Dubin? 18 would be then hired by Jeffrey? 18 A. I don't believe -- I have no 19 A. That was one of my 19 recollection of it. 20 responsibilities. 20 Q. Did you ever have sexual contact 21 Q. Do you recall interviewing Johanna? 21 with Johanna? 22 A. I don't recall the exact interview, 22 MR. PAGLIUCA: Object to the form 23 no. 23 and foundation. You need to give me an 24 Q. Do you know what tasks Johanna was 24 opportunity to get in between the 25 hired to performance? 25 questions. 16 (Pages 58 to 61) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 8 of 38 Page 62 Page 64 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Anything that involves consensual 2 Q. Did you have sex with her? 3 sex on your part, I'm instructing you 3 MR. PAGLIUCA: This is the same 4 not to answer. 4 instruction about consensual or 5 Q. Did you ever have sexual contact 5 nonconsensual. 6 with Johanna? 6 Q. Was Emmy under the age of 18 when 7 A. Again, she is an adult -- 7 you hired her? 8 Q. I'm asking you, did you ever have 8 A. No. I didn't hire her, as I said, 9 sexual contact with Johanna? 9 Jeffrey did. 10 A. I've just been instructed not to 10 Q. Did Emmy ever have sex with 11 answer. 11 Jeffrey? 12 Q. On what basis? 12 MR. PAGLIUCA: Objection to the 13 A. You have to ask my lawyer. 13 form and foundation. 14 Q. Did you ever have sexual contact 14 A. How would I know what somebody else 15 with Johanna that was not consensual on 15 did. 16 Johanna's part? 16 Q. You weren't involved in the sex 17 MR. PAGLIUCA: You can answer 17 between Jeffrey, Emmy and yourself? 18 nonconsensual. 18 A. We already -- 19 A. I've never had nonconsensual sex 19 Q. Were you involved with sex between 20 with anybody. 20 Jeffrey, Emmy and yourself? 21 Q. Not Annie Farmer? 21 MR. PAGLIUCA: Everyone is talking 22 MR. PAGLIUCA: Objection. 22 over each other. You heard the 23 A. I just testified I never had 23 question. 24 nonconsensual sex with anybody ever, at any 24 Again, you you know what the 25 time, at anyplace, at any time, with anybody. 25 instruction is. If there is any Page 63 Page 65 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. So if Johanna were to testify that 2 consensual issue involved, I instruct 3 she did not consent to a sexual act that you 3 you not to answer. 4 participated in -- 4 A. Moving on. 5 A. I just told you I have never ever 5 Q. So you are refusing to answer that 6 under any circumstances with anybody, at any 6 question? 7 time, in anyplace, in any form had 7 A. I've been instructed by my lawyer. 8 nonconsensual relations with anybody. 8 Q. Did you ever have sex with Jeffrey, 9 Q. Did you introduce Johanna to Prince 9 Emmy, Virginia and yourself when Virginia was 10 Andrew? 10 underage? 11 MR. PAGLIUCA: Objection to the 11 A. Absolutely not. 12 form and foundation. 12 MR. PAGLIUCA: We've been going for 13 A. I've, again, read that Johanna 13 about an hour. I would like to take a 14 claimed that she met or that she said she met 14 five-minute break, please. 15 Prince Andrew. I don't know if I was the one 15 MS. McCAWLEY: I'm almost done. 16 who made the introduction or not. 16 MR. PAGLIUCA: You are not going to 17 Q. Do you know a female by the name of 17 allow a break. 18 Emmy Taylor? 18 MS. McCAWLEY: As soon as I get 19 A. I do. 19 through my line of questioning, which is 20 Q. How do you know her? 20 perfectly appropriate. 21 A. Emmy was my assistant. 21 Q. Did Emmy Taylor travel with you and 22 Q. So she worked for you? 22 Jeffrey to Europe? 23 A. Yes. 23 A. I'm sure she did. 24 Q. Did you hire her? 24 Q. What is she doing today? 25 A. Again, Jeffrey hired people. 25 A. I have no idea. 17 (Pages 62 to 65) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 9 of 38 Page 78 Page 80 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 2 all, except for this story. 3 massages? 3 Q. Do you recall Virginia Roberts 4 A. It's important to understand that I 4 calling you because she was having a medical 5 wasn't with Jeffrey all the time. In fact, I 5 crisis and you and Jeffrey taking her to the 6 was only in the house less than half the 6 hospital? 7 time, so I cannot testify to when I wasn't in 7 A. I have heard this absurd story and 8 the house how often she came when I wasn't 8 if any part of it were true I would remember 9 there. 9 that. I do not. 10 What I can say is that I barely 10 Q. You don't remember taking her to 11 would remember her, if not for all of this 11 the hospital? 12 rubbish, I probably wouldn't remember her at 12 A. It's not that I don't remember it, 13 all, except she did come from time to time 13 it didn't happen. 14 but I don't recollect her coming as often as 14 Q. How do you know it didn't happen? 15 she portrayed herself. 15 A. That's the sort of memory you would 16 Q. How many times a day on an average 16 recall. 17 day would Jeffrey Epstein get a massage? 17 Q. Do you recall, you said you don't 18 MR. PAGLIUCA: Objection to the 18 remember her being at the New York mansion. 19 form and foundation. 19 When you were in New York would you stay at 20 A. When I was at the house and when I 20 the New York mansion with Jeffrey? 21 was there with him, he received a massage, on 21 A. I stayed from time to time. 22 average, about once a day. 22 Q. Do you recall Virginia being at the 23 Q. Just once? 23 New York mansion when Prince Andrew came to 24 A. Yes. 24 visit? 25 Q. Were there days when he received 25 MR. PAGLIUCA: Objection to the Page 79 Page 81 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 four or five? 2 form and foundation. 3 MR. PAGLIUCA: Objection to the 3 A. Like I told you, I don't recall her 4 form and foundation. 4 being at the house at all. 5 A. When I was present at the house, I 5 Q. How many homes does Jeffrey have? 6 never saw something like that. 6 MR. PAGLIUCA: Objection to the 7 Q. Do you know if Virginia was 7 form and foundation. 8 required to be on call at all times to come 8 A. When I was working for him, I think 9 to the house if Jeffrey wanted her there? 9 he had six maybe. 10 MR. PAGLIUCA: Objection to the 10 Q. Would Virginia stay with him in 11 form and foundation. 11 those homes? 12 A. I have no idea of the arrangements 12 MR. PAGLIUCA: Objection to the 13 that Virginia made with Jeffrey. 13 form and foundation. 14 Q. When Virginia was in New York, 14 A. I can only testify for when I was 15 would Virginia sleep at Jeffrey's mansion in 15 present with him and I cannot say what she 16 New York? 16 did when I wasn't present with him. 17 MR. PAGLIUCA: Objection to the 17 Q. When you were present, would 18 form and foundation. 18 Virginia stay in the homes with him? 19 A. I don't recollect her being in New 19 A. I don't recall her staying in the 20 York and I have no idea where she slept. 20 houses. 21 Q. You don't ever remember seeing 21 Q. Did you train Virginia on how to 22 Virginia Roberts in New York? 22 recruit other girls for massages? 23 MR. PAGLIUCA: Objection to the 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 24 form and foundation. 25 A. I would barely recollect her at 25 A. No. 21 (Pages 78 to 81) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 10 of 38 Page 82 Page 84 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Q. Did you train Virginia on how to 2 30 girls -- 3 recruit other girls to perform sexual 3 A. I did not count the number of girls 4 massages? 4 and I did read the police report. I can only 5 MR. PAGLIUCA: Objection to the 5 testify to what I read. 6 form and foundation. 6 Q. So you are aware that the police 7 A. No. And it's absurd and her entire 7 report contains reports from 30 underage 8 story is one giant tissue of lies and 8 girls? 9 furthermore, she herself has -- if she says 9 A. I can't testify to what the girls 10 that, you have to ask her about what she did. 10 said. I can only testify to the fact that I 11 Q. Does Jeffrey like to have his 11 read a police report that stated that. 12 nipples pinched during sexual encounters? 12 Q. Were you working for Jeffrey -- you 13 MR. PAGLIUCA: Objection to form 13 said you worked for him off an on until 2009, 14 and foundation. 14 is that correct? 15 A. I'm not referring to any advice on 15 A. I helped out from time to time. 16 my counsel. I'm not talking about any adult 16 Q. So you were working with him during 17 sexual things when I was with him. 17 the time period when these underage girls 18 Q. When Jeffrey would have a massage, 18 were visiting Jeffrey's home? 19 would he request that the masseuse pinch his 19 MR. PAGLIUCA: Objection to the 20 nipples while he was having a massage? 20 form and foundation. 21 A. I'm not talking about anything with 21 A. I was not -- what year, I need 22 consensual adult situation. 22 years. 23 Q. What about with underage -- 23 Q. How about let's say 2005? 24 A. I am not aware of anything. 24 A. I'm not sure I was at the house at 25 Q. You are not aware of Jeffrey 25 all in 2005, maybe one day, maybe. Page 83 Page 85 1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Epstein ever having sex with an underage 2 Q. How about 2004? 3 minor and asking them to pinch his nipples? 3 A. I was present for his mother's -- 4 A. I am not. 4 his mother died in 2004 so I was there for 5 Q. So I'm going to direct you to, I 5 his mother's death and the funeral and I was 6 believe it's Maxwell Exhibit 1, the police 6 at the house maybe a handful of days, again. 7 report. 7 Q. I would like to direct you to, you 8 Are you aware that over 30 under 8 have it pulled together now, it's page 39, 9 age minors gave testimony to police that they 9 Bates stamped Giuffre 00040? 10 were engaged in sexual acts during, 10 A. Can you repeat that, please. 11 quote-unquote, massages. 11 Q. Sure. 00040. 12 MR. PAGLIUCA: The witness needs to 12 A. Yes. 13 find Exhibit 1. Exhibit 1 -- if you can 13 Q. At the top of that document, about 14 hand me that please. 14 three lines down, you see the redacted 15 Q. So now with respect to the police 15 portions where there is black so it blacks 16 report, are you aware that over 30 underage 16 out the name. 17 girls, meaning under the age of 18 gave 17 A. I see black redacted portions. 18 reports to police that they were assaulted 18 Q. That's a black redaction of the 19 sexually by Jeffrey Epstein during massages? 19 name of the minor and there is -- I will 20 MR. PAGLIUCA: Objection to the 20 represent for the record that's what it is. 21 form and foundation. 21 You can contest that but I'm not asking about 22 A. I read the police report. That's 22 the name of the minor. 23 all I can testify to. 23 Five lines down, it says, She was 24 Q. Are you aware of what is in the 24 just 16 years of age. 25 police report? Are you aware that there were 25 Do you see that? 22 (Pages 82 to 85) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 11 of 38 Page 94 Page 96 1