gov.uscourts.nysd.447706.1335.1.pdf

Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 1 of 465 EXHIBIT 6 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 2 of 465 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 3 of 465 Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 4 of 465 Page 3 1 2 THE VIDEOGRAPHER: We are now on 3 the record and recording. This begins 4 disk No. 1 in the deposition of 5 Ghislaine Maxwell in the matter of 6 Virginia Giuffre versus Ghislaine 7 Maxwell in the U.S. District Court for 8 the Southern District of New York. 9 Today is April 22, 2016 the time is 10 9:04 a.m.. This deposition is being 11 taken at 575 Lexington Avenue in New 12 York at the request of Sigrid McCawley 13 of Boies Schiller & Flexner. 14 The videographer is James Christe 15 and the court reporter is Leslie Fagin. 16 Will counsel state their appearance and 17 whom they represent and then court 18 reporter swear in Ms. Maxwell. 19 MS. McCAWLEY: My name is Sigrid 20 McCawley with my colleague Meredith 21 Schultz. We are with Boies Schiller & 22 Flexner. We represent Ms. Giuffre. 23 MR. EDWARDS: Brad Edwards. I also 24 represent Ms. Giuffre. 25 MR. CASSELL: Paul Cassell, I also Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 5 of 465 Page 4 1 G Maxwell - Confidential 2 represent Ms. Giuffre. 3 MR. PAGLIUCA: Jeff Pagliuca and 4 Laura Menninger on behalf of Ms. 5 Maxwell. 6 G H I S L A I N E M A X W E L L, called 7 as a witness, having been duly sworn by a 8 Notary Public, was examined and testified as 9 follows: 10 EXAMINATION BY 11 MS. McCAWLEY: 12 Q. Good morning. I'm going to explain 13 some of the rules that will happen with 14 respect to depositions. 15 Have you ever been deposed before? 16 A. I have not. 17 Q. What is going to happen here, we 18 have a court reporter and a videographer. 19 What they do is take down the words that we 20 say so when I ask you a question they will 21 record what you say in response to that. So 22 we have to be mindful that in order for them 23 to do their job we can't talk over each 24 other. 25 Another issue you have to be weary Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 6 of 465 Page 5 1 G Maxwell - Confidential 2 of is that in a response, you can't give a 3 nonverbal response, in other words, nodding a 4 yes or no, they need to hear verbal response 5 so they can record it on their transcript. 6 So that's important for you to remember as we 7 go through the day. If you forget, I will be 8 sure to remind you. 9 Is there anything that would 10 prevent you from giving truthful testimony 11 today? 12 A. There is not. 13 Q. You are not on any medications or 14 anything that would inhibit your ability to 15 remember or give truthful testimony? 16 A. I am not. 17 MR. PAGLIUCA: Could you identify 18 the assistant in the room. 19 MS. McCAWLEY: This is Emma Rosen 20 from our New York office. She is a 21 paralegal. 22 Q. Ms. Maxwell, can you please state 23 your address for the record? 24 A. Currently 25 Q. What is your date of birth? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 7 of 465 Page 6 1 G Maxwell - Confidential 2 A. 3 Q. When did you first recruit a female 4 to work for Mr. Epstein? 5 MR. PAGLIUCA: I object to the form 6 and foundation of the question. I 7 believe this is confidential 8 information. I ask anyone who is not 9 admitted in this case be excused from 10 the room, please. 11 MS. McCAWLEY: So the response to 12 that question would -- 13 MR. PAGLIUCA: The subject matter 14 of this question is confidential and I'm 15 designating it as confidential. 16 MS. McCAWLEY: I just want to make 17 that clear for the record. 18 MR. EDWARDS: So we don't delay the 19 deposition I will step out of the room 20 but I think it's important to lay the 21 record that -- 22 MR. PAGLIUCA: I'm sorry, you are 23 not admitted in this proceeding so you 24 are not entitled to make any record. If 25 Ms. McCawley wants to make a record she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 8 of 465 Page 7 1 G Maxwell - Confidential 2 can. 3 MR. EDWARDS: I can make a record 4 right now. 5 MR. PAGLIUCA: Maybe we should get 6 the judge on the phone and talk about 7 it. 8 MR. EDWARDS: The record will be 9 short. This is the precise reason why 10 Ms. Giuffre wants me in this case and 11 I'm unable to effectively represent her 12 at this time because I am unable to have 13 access to the confidential information 14 which includes apparently the entire 15 deposition of Ms. Maxwell. But for the 16 sake of not further delaying this, I 17 will be outside the room. 18 MS. McCAWLEY: Thank you. 19 A. I would like to just -- wait for 20 him to leave. 21 Q. That's fine. 22 A. I would just like to clarify the 23 address. I'm in the process of selling the 24 house so while while I still receive mail 25 there, it's not my actual physical address. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 9 of 465 Page 8 1 G Maxwell - Confidential 2 It's in the process of being sold. It still 3 requires some final paperwork to be done, so 4 just for the purposes of clarity. 5 Q. Do you have a new address where you 6 will be living? 7 A. I do not. 8 Q. For the purpose of the record, if 9 there is something I ask you that you later 10 remember something else or need to correct 11 your testimony in some way, you can do that, 12 just let me know what it is and we will go 13 back to that question and can you clarify. 14 A. Of course. I just wanted to be 15 clear, there is still some paperwork pending 16 for final release, but it's in the process of 17 sale. But I don't have another address 18 currently, so whilst that should still be of 19 record that the mail could be forwarded 20 there, so for purposes of clarity I wanted to 21 be clear. 22 Q. I appreciate that. 23 So Ms. Maxwell, when did you first 24 recruit a female to work for Mr. Epstein? 25 MR. PAGLIUCA: Again. I object to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 10 of 465 Page 9 1 G Maxwell - Confidential 2 form and foundation of the question. 3 Q. You can answer the question. 4 A. First of all, can you please 5 clarify the question. I don't understand 6 what you mean by female, I don't understand 7 what you mean by recruit. Please be more 8 clear and specific about what you are 9 suggesting. 10 Q. Are you a female, is that the sex 11 that you are? 12 A. I am a female. 13 Q. That's what I'm referring to a 14 female and I'm asking you when you first, the 15 very first time you recruited a female to 16 work for Mr. Epstein? 17 A. Again, I don't understand what 18 female -- I am a 54 year old women. 19 Q. I'm not making it age, any age of a 20 female that you recruited to work for Mr. 21 Epstein? 22 A. Again, I was somebody who hired a 23 number of people to work for Mr. Epstein and 24 hiring is one of my functions. 25 Q. And when is the first time you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 11 of 465 Page 10 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 3 female? 4 A. As best as I can recollect, a woman 5 the age probably of about 40 or 50 was in 6 sometime in 1992. 7 Q. How long did you work for Mr. 8 Epstein? 9 A. I started working for him at some 10 point in 1992 and the nature of my work 11 relationship with him changed over time so 12 from around 2002, 2003, the work lessened 13 considerably. 14 Q. When did you -- 15 MR. PAGLIUCA: Can I interject for 16 a moment. If we are talking about 17 background -- 18 MS. McCAWLEY: I'm in the middle of 19 a question. Let me finish it and then 20 can you interject. 21 Q. When you say 2002 to 2003 that the 22 work lessened, when did you complete working 23 for Mr. Epstein; when was the last time you 24 were employed by him, the last date? 25 A. I believe I still was doing -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 12 of 465 Page 11 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009. 4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine. 9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential. 14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions. 17 MR. PAGLIUCA: So we will keep it 18 as confidential. 19 Q. When you were first employed by him 20 in 1992, what were you hired to do? 21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses. 24 Q. Did your duties change over the 25 course of 1992 to 2009? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 13 of 465 Page 12 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. My job entailed running the homes 5 that he had but much more importantly, most 6 of the houses had construction and so whilst 7 in 1992 there was no construction project, 8 there was construction projects that began 9 after that time and I was in charge not only 10 of hiring architects, I was also in charge of 11 all the filings or overseeing that, like a 12 general contractor would. 13 I also helped with hiring the 14 architects, hiring the builders, reviewing 15 the contracts for the builders, coordinating 16 the building projects, coordinating how the 17 projects would layout, the timing of the 18 projects and all the various materials that 19 they would require to run a very substantial 20 building project. That's the nature of the 21 job I was dealing with. 22 Q. How old was the youngest female you 23 ever hired to work for Jeffrey? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 14 of 465 Page 13 1 G Maxwell - Confidential 2 Q. You can answer. 3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey. 6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18? 9 A. Never. 10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes? 13 MR. PAGLIUCA: Object to the form 14 foundation. 15 A. Can you repeat the question? 16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes? 18 MR. PAGLIUCA: Same objections. 19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come. 24 Q. Anybody that is not a friend of 25 yours. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 15 of 465 Page 14 1 G Maxwell - Confidential 2 Any female under the age of 18, did 3 you invite them to come to Jeffrey's home? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. Again, as I said, I am not aware of 7 inviting anybody other than friends of mine 8 who have children to the house. 9 Q. Did you invite Virginia Giuffre to 10 come to Jeffrey Epstein's home when she was 11 under the age of 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. Virginia Roberts held herself out 15 as a masseuse and invited herself to come and 16 give a massage. 17 Q. My question is, did you invite 18 Virginia Roberts when she was under the age 19 of 18 to come to Jeffrey Epstein's home? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. Again, Virginia Roberts was a 23 masseuse -- 24 Q. I'm asking not asking if she was a 25 masseuse. I'm asking if you invited her to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 16 of 465 Page 15 1 G Maxwell - Confidential 2 come to Jeffrey Epstein's home? 3 A. Again, there would be no course to 4 have a conversation with Virginia unless she 5 held herself out to be a masseuse. 6 Q. I'm not asking that question. I'm 7 asking if you invited her to come to Jeffrey 8 Epstein's home when she was under the age of 9 18? 10 A. Again, I repeat, she was a masseuse 11 and in the form and as my job, I was to have 12 people who he wanted for various things 13 including massage. She came as a masseuse. 14 Q. So you invited her to his home to 15 come to give a massage, is that correct? 16 MR. PAGLIUCA: Object to the form 17 and foundation. Misstates the witness' 18 testimony. 19 A. Again, I did not invite Virginia 20 Roberts. She came as a masseuse. 21 Q. She who invited her to come as a 22 masseuse, she just showed up at the front 23 door? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 17 of 465 Page 16 1 G Maxwell - Confidential 2 A. Ms. Roberts held herself out -- 3 Q. I'm not asking how she held herself 4 out. I'm asking how she arrived at the home. 5 Did you meet her and invite her to come to 6 the home or how did she arrive there? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Ms. Roberts held her to be a 10 masseuse and her mother drove her to the 11 house. 12 Q. When did you first meet Virginia 13 Roberts? 14 A. I don't have a recollection of the 15 first meeting. 16 Q. Do you recall meeting her at 17 Mar-a-Lago? 18 A. Like I said, I don't have a 19 recollection of meeting Ms. Roberts. 20 Q. So you recall Ms. Roberts being 21 brought to the home by her mother, is that 22 your testimony? 23 A. That is my testimony. 24 Q. And that is the first time you met 25 her? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 18 of 465 Page 17 1 G Maxwell - Confidential 2 A. Like I said, I don't recall meeting 3 her the first time. I do remember her mother 4 bringing her to the house. 5 Q. Are you a member at Mar-a-Lago? 6 A. No. 7 Q. Have you visited Mar-a-Lago? 8 A. Yes. 9 Q. Did you visit Mar-a-Lago in the 10 year 2000? 11 A. I'm pretty sure I did. 12 Q. When Ms. Roberts arrived at the 13 home with her mother, what happened? 14 A. I spoke to her mother outside of 15 the house and she -- what I don't recall is 16 exactly what happened because I was talking 17 to her mother the entire she was in the 18 house. 19 Q. Did you introduce Ms. Roberts to 20 Jeffrey Epstein? 21 A. I don't recall how she actually met 22 Mr. Epstein. As I said, I spoke to her 23 mother the entire time outside the house. 24 Q. Did you walk Ms. Roberts up to the 25 upstairs location at the Palm Beach house to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 19 of 465 Page 18 1 G Maxwell - Confidential 2 meet Mr. Epstein? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. You can answer. 6 A. I just explained. 7 A. I spent the entire time talking to 8 Virginia's mother outside the house so the 9 answer to the question is no. 10 Q. No, did you not walk her up and 11 introduce her to Mr. Epstein? 12 A. I just said no. 13 Q. Did you participate in a massage 14 this first time when she first came to the 15 home and you were speaking with her mother, 16 she was in the home, is that correct, you 17 brought her into the home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I will repeat again, I was standing 21 outside with her mother so very difficult for 22 me to do anything else at that time so no, I 23 did not take her upstairs. 24 Q. Did you participate -- 25 A. Virginia lied 100 percent about Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 20 of 465 Page 19 1 G Maxwell - Confidential 2 absolutely everything that took place in that 3 first meeting. She has lied repeatedly, 4 often and is just an awful fantasist. So 5 very difficult for anything to take place 6 that she repeated because I was with her 7 mother the entire time. 8 Q. So did you have -- did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 Q. Yes or no? 15 A. No. 16 Q. Have you ever given a massage with 17 Virginia Roberts in the room and Jeffrey 18 Epstein? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. No. 22 Q. Have you ever given Jeffrey Epstein 23 a massage? 24 MR. PAGLIUCA: Object to the form, 25 foundation. And I'm going to instruct Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 21 of 465 Page 20 1 G Maxwell - Confidential 2 you not to answer that question. I 3 don't have any problem with you asking 4 questions about what the subject matter 5 of this lawsuit is, which would be, as 6 you've termed it, sexual trafficking of 7 Ms. Roberts. 8 To the extent you are asking for 9 information relating to any consensual 10 adult interaction between my client and 11 Mr. Epstein, I'm going to instruct her 12 not to answer because it's not part of 13 this litigation and it is her private 14 confidential information, not subject to 15 this deposition. 16 MS. McCAWLEY: You can instruct her 17 not to answer. That is your right. But 18 I will bring her back for another 19 deposition because it is part of the 20 subject matter of this litigation so she 21 should be answering these questions. 22 This is civil litigation, deposition and 23 she should be responsible for answering 24 these questions. 25 MR. PAGLIUCA: I disagree and you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 22 of 465 Page 21 1 G Maxwell - Confidential 2 understand the bounds that I put on it. 3 MS. McCAWLEY: No, I don't. I will 4 continue to ask my questions and you can 5 continue to make your objections. 6 Q. Did you ever participate from the 7 time period of 1992 to 2009, did you ever 8 participate in a massage with Jeffrey Epstein 9 and another female? 10 MR. PAGLIUCA: Objection. Do not 11 answer that question. Again, to the 12 extent you are asking for some sort of 13 illegal activity as you've construed in 14 connection with this case I don't have 15 any problem with you asking that 16 question. To the extent these questions 17 involve consensual acts between adults, 18 frankly, they're none of your business 19 and I will instruct the witness not to 20 answer. 21 MS. McCAWLEY: This case involves 22 sexual trafficking, sexual abuse, 23 questions about her having interactions 24 with other females is relevant to this 25 case. She needs to answer these Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 23 of 465 Page 22 1 G Maxwell - Confidential 2 questions. 3 MR. PAGLIUCA: I'm instructing her 4 not to answer. 5 MS. McCAWLEY: Then we will be back 6 here again. 7 Q. Have you ever given a massage to 8 Mr. Epstein with a female that was under the 9 age of 18? 10 A. Can you repeat the question? 11 Q. Yes. Have you ever given a massage 12 to Mr. Epstein with a female that was under 13 the age of 18? 14 A. No. 15 Q. Have you ever observed Mr. Epstein 16 having a massage given by an individual, a 17 female, who was under the age of 18? 18 A. No. 19 Q. Have you ever observed females 20 under the age of 18 in the presence of 21 Jeffrey Epstein at his home? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. Again, I have friends that have 25 children -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 24 of 465 Page 23 1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 3 talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 25 of 465 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 26 of 465 Page 25 1 G Maxwell - Confidential 2 You will see some redactions in 3 this report, Ms. Maxwell, the redacted 4 information is redacted because it reveals 5 the name of a minor, someone who is under the 6 age of 18. 7 On page 28, in the third paragraph, 8 about halfway down, it says, Roberts stated 9 she performed the massage naked. At the 10 conclusion of this massage, Epstein paid 11 RobSON $200 for the massage. He explained, I 12 know you are not comfortable put I will pay 13 you if you bring some girls. He told her the 14 younger the better. Robson stated once tried 15 to bring a 23 year old to Epstein and he 16 stated the female was too old. 17 Have you heard Mr. Epstein use the 18 phrase the younger the better? 19 A. I have no recollection of hearing 20 that. 21 Q. Have you used the phrase in talking 22 to Ms. Roberts and asking her to recruit 23 females for Mr. Epstein, the younger the 24 better? 25 MR. PAGLIUCA: Object to the form Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 27 of 465 Page 26 1 G Maxwell - Confidential 2 and foundation of the question. 3 A. First of all, can you break the 4 question apart. 5 Q. Have you used the phrase the 6 younger the better in speaking to Ms. Roberts 7 and asking her to recruit females for Jeffrey 8 Epstein? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 Q. You can answer. It's yes or no. 12 A. No, that's absolutely not true, on 13 the second part of your question, I have not 14 asked Virginia to recruit females and the 15 first part of your question, if you can 16 repeat that again, the question you asked. 17 Q. Will you read back the question. 18 (Record read.) 19 A. I believe I answered the later part 20 of the question. The first part of the 21 question, it's impossible for me to recall 22 events that took place 16 years ago but it 23 doesn't sound like something I would say. 24 Q. On page 28, that same paragraph, 25 Roberts was asked how many girls in total she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 28 of 465 Page 27 1 G Maxwell - Confidential 2 brought to Epstein. Robson stated that she 3 can remember, Robson stated that she brought 4 and, it's redacted there, and the victim in 5 this case. 6 Let me ask my question, I have a 7 question pending right now. 8 Are you testifying that you are 9 unaware of any underage, under the age of 18, 10 females coming to Jeffrey Epstein's home to 11 perform massages? 12 MR. PAGLIUCA: Object to the form 13 foundation. 14 A. You need to straddle that question 15 in a different time period. When I was 16 there, at the time I was present, the people 17 that gave Jeffrey, men and women who gave 18 Jeffrey massages were adults over the age of 19 18. 20 Q. Never in your time at any of 21 Jeffrey Epstein's homes were you present when 22 a female under the age of 18 was there to 23 give Jeffrey Epstein a massage? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 29 of 465 Page 28 1 G Maxwell - Confidential 2 A. First of all, as I said when I was 3 present -- 4 Q. It is a yes or no. 5 A. No, it is not. 6 Q. You can answer the question in full 7 but please provide yes or no as an initial 8 matter. 9 A. I cannot answer yes or no, it's not 10 bounded by time. It's entirely possible I 11 could have been in a room or even in the 12 vicinity of Palm beach when somebody came and 13 I would not know. How would I know when 14 somebody was in the house. There is no way I 15 can know. 16 Q. Did you stay at Jeffrey Epstein's 17 home when you were in Palm Beach? 18 A. Most of the time. 19 Q. So how is it that you wouldn't know 20 if there was a female in the home under the 21 age of 18 if you were staying there? 22 A. Well, first of all, when I was 23 staying there, the house is actually quite 24 large and I have a very busy job and I had an 25 office with a door so the door would be shut Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 30 of 465 Page 29 1 G Maxwell - Confidential 2 and I would be working. I'm not responsible 3 for what Jeffrey does and I don't always pay 4 attention to what happens in the house. I'm 5 very busy. 6 Q. So you're testifying that you never 7 observed a female under the age of 18 at 8 Jeffrey Epstein's West Palm Beach home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. I already answered that question, I 12 believe. 13 Q. You didn't answer my question. 14 A. I did. 15 Q. Did you observe a female under the 16 age of 18 at Jeffrey Epstein's home in Palm 17 Beach? 18 A. Like I said, I work, I don't sit 19 there and watch people coming in and out of 20 the house. I cannot possibly tell you if I'm 21 in the home that somebody was there that I 22 did not see, I cannot comment on it, I have 23 no idea. 24 Q. Did you observe females at Jeffrey 25 Epstein's home that were laying out topless Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 31 of 465 Page 30 1 G Maxwell - Confidential 2 in the back of the home, in other words 3 without a shirt on? 4 A. So that's just another of 5 Virginia's lies. So let's be clear, at the 6 time when I was there and present, frequently 7 at the house, it was unusual to see people 8 without their clothes on. 9 Q. When you say unusual, did you 10 observe people without their clothes at 11 Jeffrey Espstein's home? 12 A. Can I answer. Sometimes people in 13 the privacy of a house and swimming pool, I 14 have seen people from time to time take their 15 top off. I have seen people from time to 16 time do that. Very unusual. Naked people 17 around the people at any frequent period of 18 time, I have never seen. 19 Q. Were they under the age of 18? 20 A. As I was saying, people when I was 21 in the house, were of adult age, if they were 22 children, friends of my family or friends 23 that were there, they may well have been 24 because I have nieces and nephews under the 25 age of 18, I cannot testify to anybody else Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 32 of 465 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 33 of 465 Page 32 1 G Maxwell - Confidential 2 Q. Did you ever hire a masseuse that 3 was under the age of 18? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 Q. Did you? 7 A. Again, I don't hire massage 8 therapists, so that was not my job. 9 Q. You just said you did, you just 10 said you hired massage therapists for Jeffrey 11 Epstein, I'm asking if you hired a massage 12 therapist who was under the age of 18? 13 A. Let me correct myself. When I 14 meant hire, I didn't mean hire in the way you 15 are doing it. What I say is that I went to 16 spas and I met people and if they did home 17 visits, Jeffrey would then, in fact, hire 18 them. I'm not responsible for hiring 19 someone. And they were not full-time, so 20 it's not a correct characterization. 21 Q. Did you ever, your term is meet, 22 did you ever meet a person that was under the 23 age of 18 that you -- that Jeffrey then hired 24 as a masseuse? 25 MR. PAGLIUCA: Object to the form Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 34 of 465 Page 33 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, Virginia Roberts who 4 you are referring to was a masseuse aged 17, 5 we all now know, so your story that you keep 6 pushing out to the press that she was a 15 7 year old -- you and I both know was a lie, 8 correct. 9 Q. You are not sentencing my question. 10 A. You and I both know that was a lie, 11 correct. 12 Q. You are not answering my question. 13 I'm asking you whether you ever met a female 14 under the age of 18 that Jeffrey then hired 15 as a masseuse? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. The only person I can talk about 19 who clearly was a massage age 17, a masseuse, 20 was Virginia. 21 Q. Did you meet her and then introduce 22 her to Jeffrey? 23 A. I don't know. I already testified 24 I don't recall meeting her. 25 (Maxwell Exhibit 2, email, marked Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 35 of 465 Page 34 1 G Maxwell - Confidential 2 for identification.) 3 Q. So I'm showing you a document that 4 we have marked as Maxwell Exhibit 2. It's a 5 document you produced in this matter labeled 6 confidential GM 00109. It's dated Sunday 7 June 12, 2011. It's from Jeffrey Epstein to 8 you. If you can turn to page 4 -- sorry, can 9 you turn to the first page, the cover page 10 initially which is 00109. If you look under 11 the time stamp it says, June 12, 2011 at 4:12 12 p.m., it says 13 Is that your email address? 14 A. It is. 15 Q. Under that it says, Thank you. I 16 have it now and I'm working on a letter, a 17 little, I will send the final version 18 tomorrow and what ever it is will be 19 factually accurate. 20 Do you see that on page 1? 21 A. I do. 22 Q. Then I would like you to turn to 23 page 4 please. The second paragraph down on 24 page 4, it states, After some thought, I 25 recall that I first met Ms. Roberts when she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 36 of 465 Page 35 1 G Maxwell - Confidential 2 was working at a premier resort claiming to 3 be 18 years old and a professional masseuse? 4 MR. PAGLIUCA: What line are you 5 on, counsel. 6 MS. McCAWLEY: Second paragraph 7 down. 8 MR. PAGLIUCA: I got it. 9 Q. Is that a statement that you wrote? 10 A. It appears to be. 11 Q. So does that correct your testimony 12 that you did meet Ms. Roberts at Mar-a-Lago? 13 A. Again, this was written in, when 14 were you saying? 15 Q. 2011. 16 A. So by 2011, Ms. Roberts had already 17 perpetrated so many lies and stories it's 18 hard for me to accurately tell you today what 19 I remember back then. As I sit here today, 20 the testimony I give you today, I do not 21 recollect it. 22 Q. Do you have a reason to say that 23 this document that you wrote is incorrect? 24 A. It's in 2011, I can't possibly tell 25 you what I remember in 2011. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 37 of 465 Page 36 1 G Maxwell - Confidential 2 Q. Are you questioning that this 3 document is incorrect, this document -- this 4 email that you wrote? 5 A. I wrote an email. I was trying to 6 be accurate, so who knows, with all the 7 rubbish that you guys have put out in the 8 press that I read, maybe in the moment I 9 wrote it a memory came to me that I don't 10 know, but as I sit here today and the 11 testimony I gave you today is I don't 12 recollect it. 13 Q. Does this refresh your recollection 14 that you recalled meeting Ms. Roberts at 15 Mar-a-Lago? 16 A. It does not. 17 Q. So your testimony today is that you 18 don't remember meeting Ms. Roberts at 19 Mar-a-Lago? 20 A. I do not. 21 I just want to clarify, when you 22 read so much stuff and so much rubbish that 23 comes out from Virginia Roberts, you don't 24 know what's up and down, at the time I wrote 25 this I believe I had a memory but as I sit Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 38 of 465 Page 37 1 G Maxwell - Confidential 2 here today I do not. 3 Q. Ms. Maxwell, when did you first 4 meet ? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 A. I have no idea when I met her. 8 Q. Do you know how old she was when 9 you met her? 10 A. I have no idea how old she was when 11 I met her. 12 Q. Is it possible she was 13 years old 13 when you first met her? 14 MR. PAGLIUCA: Object to the form 15 and foundation. 16 A. 21 Q. I understand 22 23 I'm asking if was 13 24 years old when you first met her? 25 A. I have no idea. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 39 of 465 Page 38 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met 3 her? 4 A. I have no idea how old she was when 5 I first met her. 6 Q. Did she look like a child when you 7 first met her? 8 A. I don't remember what she looked 9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I 12 saw her. 13 Q. When was the first time you met 14 her? 15 A. Again, I just told you, I don't 16 recall the first time I met her. 17 Q. Did travel with you 18 on Jeffrey's planes? 19 A. I wouldn't remember if was on 20 the plane or not. 21 Q. Did you ever have sex with 22 23 A. No. 24 Q. Did you ever observe Jeffrey having 25 sex with ? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 40 of 465 Page 39 1 G Maxwell - Confidential 2 A. No. 3 Q. Were you aware that Jeffrey was 4 having sexual contact with when 5 she was 13 years old? 6 MR. PAGLIUCA: Object to the form 7 and foundation. 8 A. I would be very shocked and 9 surprised if that were true. 10 Q. Were you in the house when 11 was in the house in a private area 12 with Jeffrey Epstein? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 A. Can you repeat the question. 16 Q. Were you ever in the Palm Beach 17 house when Jeffrey Epstein was in the house 18 with ? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I've already testified that I have 22 met her and that she was there 23 I don't understand what your 24 question is asking. 25 Q. So you have never seen Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 41 of 465 Page 40