gov.uscourts.nysd.447706.1335.2.pdf

Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 1 of 73 EXHIBIT D  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 2 of 73 Confidential UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 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 (866) 624-6221 MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 3 of 73 Confidential Page 2 Page 4 1 2 APPEARANCES: 1 3 On Behalf of the Plaintiff: 2 MR. EDWARDS: Brad Edwards, also 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street 3 representing the plaintiff, Virginia 5 BY: Armonk, New York 10504 DAVID BOIES, ESQUIRE 4 Giuffre. 6 5 MR. POTTINGER: Stan Pottinger, BOIES SCHILLER & FLEXNER,LLP 7 401 East Las Olas Boulevard 6 also representing the plaintiff. 8 BY: Fort Lauderdale, Florida 33301 MEREDITH SCHULTZ, ESQUIRE 7 MR. CASSELL: Paul Cassell, from SIGRID McCAWLEY, ESQUIRE 8 Salt Lake City, Utah, also representing 9 SANDRA PERKINS, PARALEGAL 10 9 Ms. Giuffre. 11 FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, P.L. 10 MR. PAGLIUCA: Jeff Pagliuca and 425 N. Andrews Avenue 11 Laura Menninger, on behalf of Ms. 12 Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE 12 Maxwell. 13 13 And Ms. McCawley has also entered 14 PAUL G. CASSELL, ESQUIRE 383 South University Street 14 the room, and we have an assistant from Salt Lake City, Utah 84112 15 16 15 Boies Schiller from the Fort Lauderdale J. STANLEY POTTINGER, PLLC 16 office here today as well today. 17 49 Twin Lakes Road South Salem, New York 10590 17 THE VIDEOGRAPHER: Will the court 18 19 BY: STAN POTTINGER, ESQUIRE 18 reporter please swear in the witness. On Behalf of Defendant: 19 G H I S L A I N E M A X W E L L, 20 HADDON MORGAN FOREMAN 20 called as a witness, having been duly 21 Attorneys for Defendant 150 East 10th Avenue 21 sworn by a Notary Public, was 22 Denver, Colorado 80203 22 examined and testified as follows: BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 23 EXAMINATION BY 24 Also Present: 24 MR. BOIES: 25 25 Q. Good morning, Ms. Maxwell. Page 3 Page 5 1 1 G. Maxwell - Confidential 2 THE VIDEOGRAPHER: This is DVD No. 2 3 1, Volume II, of the continued video 4 recorded deposition of Ghislaine Maxwell 5 in the matter Virginia Giuffre against 6 Ghislaine Maxwell, in the United States 7 District Court, Southern District of New 8 York. 9 This deposition is being held at 10 575 Lexington Avenue, New York, New 11 York, on July 22, 2016 at approximately 12 9:04 a.m. 13 My name is Rodolfo Duran. I am the 14 legal video specialist. The court 15 reporter is Leslie Fagin, and we are 16 both in association with Magna Legal 17 Services. 18 Will counsel please introduce 19 themselves. 20 MR. BOIES: This is David Boies, of 21 Boies, Schiller & Flexner, counsel for 22 plaintiff. 23 MS. SCHULTZ: Meredith Schultz, 24 from Boies Schiller & Flexner, counsel 25 for plaintiff. 2 (Pages 2 to 5) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 4 of 73 Confidential Page 6 Page 8 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 3 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 MR. BOIES: Excuse me, counsel. 25 MR. PAGLIUCA: I'm objecting to Page 7 Page 9 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 form and foundation, and I have an 3 3 opportunity to do that. 4 MR. BOIES: Yes, you do, but you do 5 not have an opportunity to disrupt the 6 deposition. 7 MR. PAGLIUCA: Which I'm not. 8 MR. BOIES: The court will decide 9 that, as the court has decided the 10 issues before. 11 3 (Pages 6 to 9) MAGNA9LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 5 of 73 Confidential Page 10 Page 12 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 Page 11 Page 13 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 . 3 I6 Q. You understand that you are under 7 oath, correct? 8 A. I do. 9 Q. And you understand that the oath 10 requires you to tell the truth, the whole 11 truth and nothing but the truth in response 12 to questions? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Do you? 16 A. I do understand that. 17 Q. Do you understand if you fail to do 18 that, that you could be prosecuted for 19 perjury? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I understood that is what happens 23 at these events. 24 Q. And do you understand that if you 25 say that you do not recall and in fact you do 4 (Pages 10 to 13) MAGNA9LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 6 of 73 Confidential Page 14 Page 16 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 recall, that would violate your oath? 2 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. If I don't recall, I don't recall. 6 It's not a question of whether I'm violating 7 my oath or not. I don't know. 23 Q. Were you ever on a plane with 24 Mr. Epstein when Mr. Epstein had sex with 25 anyone? Page 15 Page 17 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I know? 5 Q. Were you ever on a plane with 6 Mr. Epstein when, to your knowledge, 7 Mr. Epstein had sex with anyone? 8 A. Can you repeat the question? 9 Q. Were you ever on a plane with 10 Mr. Epstein when, to your knowledge, 11 Mr. Epstein had sex with anyone? 12 A. Not that I can recall. 13 Q. Were you ever on a plane with 14 Mr. Epstein when you saw Mr. Epstein having 15 sex with anyone? 16 A. Never. 17 Q. I want to be sure that the question 18 and answer is meeting. When you refer to 19 having sex with someone, what are you 20 referring to? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. Intercourse. 24 Q. And when you refer to intercourse, 25 what do you refer to? 5 (Pages 14 to 17) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 7 of 73 Confidential Page 18 Page 20 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 A. I think everyone here can 2 3 understand what intercourse is, is when you 4 have sex. I don't know how to say 5 intercourse any other way, having sex with 6 somebody. Perhaps you would like to define 7 it for me. 8 Q. I'm trying to get your definition 9 right now because you are the witness. When 10 you use the term intercourse, what are you 11 referring to? 11 MR. PAGLIUCA: I'm going to 12 A. I'm referring to a penis entering 12 instruct you not to answer, unless you 13 someone's vagina. 13 tie it to a specific individual related 14 14 to this case per the court's order. 15 MR. BOIES: I think the court's 16 order specifically permits this question 17 with respect to occasions related to 18 this case. If you instruct her not to 19 answer, all you're going to do is bring 20 her back. That's up to you. 21 MR. PAGLIUCA: It's up to you as 22 the questioner, Mr. Boies. Page 19 Page 21 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 I6 7 You haven't tied your question to time or individual or specific location. 8 And so unless you do that, we have an 9 open-ended question that would span from 10 the early '90s to 2000 or so, which 11 would not be tied to the key events, 12 individuals or locations of this case. 13 BY MR. BOIES: 14 Q. Let me ask you a couple more 15 questions. Then I think we probably ought to 16 call the court and get some guidance on this. 17 24 Q. Were you ever on Mr. Epstein's 25 plane when, to your knowledge, Mr. Epstein 6 (Pages 18 to 21) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 8 of 73 Confidential Page 22 Page 24 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 had oral sex with anyone 2 court case on this list, one other person. 3 A. No. 3 Q. Which one is that? 4 4 A. Haley Robson, because she has been 5 on the court papers. 6 Q. Haley who? 7 A. Robson. 8 9 1111 The only two I know is and Virginia, and one other name I recognize. 10 Q. So just to be clear, the only two 11 people listed on Maxwell Deposition Exhibit 12 26 that you know are 13 A. And Virginia Roberts, yes. 14 Q. And the only other person on -- 15 A. I don't know her, I recognize her 16 name. 17 Q. -- whose name you recognize is 18 Haley Robson, but you don't know her, never 19 met her? 20 A. I don't recall ever meeting her. 21 Q. Other than what you know from her 22 participation in this case, you don't know 23 anything about her, is that your testimony? 24 A. I don't even know -- I don't even 25 recognize what her participation is in this Page 23 Page 25 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 case. I just know I recognize her name, and I4 . 3 I can't recall right now what her involvement MR. BOIES: I will show you a 4 is, but I recognize the name. 5 document we have marked for 5 Q. Other than whatever her involvement 6 identification as Maxwell Deposition 6 in this case may be or may not be? 7 Exhibit 26. 7 A. Correct. 8 (Maxwell Exhibit 26, List of names, 8 Q. Is it fair to say it is your 9 marked for identification, as of this 9 testimony that except for that, you have no 10 date.) 10 knowledge about her at all? 11 12 13 14 15 16 Q. I would like you to go down this list and tell me which names, if any, you recognize on this list. A. Just in the way the list runs in order, I recognize the names -- by recognize, only stating that I know the name, I'm not 11 12 13 14 15 16 A. Correct. Q. And other than - , Virginia Roberts and Haley Robson, you don't know anything at all about any of the other people listed here, is that your testimony? A. I don't even know who they are. 17 making any representations about these 17 You could put any names in front of me, I 18 people. 18 wouldn't recognize them, I don't know them, I 19 Q. I understand that, and I will come 19 don't even recognize the names. 20 back and ask you, but if you don't recognize 20 Q. I think this is clear from your 21 22 23 24 25 A. - the name... . Virginia Roberts. And that's it on this list. Let me just double-check. I recognize the name, not because I know her, but just because of the 21 22 23 24 25 - last answer, but I want to be sure. It is your testimony that other than and Virginia Roberts, you never met any of these people at any homes of Mr. Epstein, is that your testimony? 7 (Pages 22 to 25) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 9 of 73 Confidential Page 26 Page 28 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 2 a massage at his home in New York, regardless 3 and foundation. 3 of where in the home it was? 4 A. I don't even know who they are, so 4 A. No. 5 I wouldn't -- I have no clue who they are, I 5 Q. Have you ever seen anyone give 6 don't know where they are, I don't know where 6 Mr. Epstein a massage at his home in Palm 7 they come from, I don't recognize -- I only 7 Beach? 8 pointed out Haley Robson because I recognize 8 A. I have. 9 the name from various documents I read. I 9 Q. Have you ever seen anyone give 10 don't have any knowledge of any other person 10 Mr. Epstein a massage in New Mexico? 11 on this list. I don't believe I've ever even 11 A. No, I can't recall. 12 seen these names. I don't know who they are 12 Q. Have you ever seen anyone give 13 at all. 13 Mr. Epstein a massage in the Virgin Islands? 14 I would not be able to identify a 14 A. I have. 15 single name on this list other than those 15 Q. Have you ever seen anyone give 16 three that I have indicated to you. 16 Mr. Epstein a massage in Paris? 17 17 A. No, I don't recall seeing that. 18 Q. Have you ever seen anyone give 19 Mr. Epstein a massage on an airplane? 20 A. No. 21 Q. Have you ever seen anyone give 22 Mr. Epstein a massage anywhere other than his 23 home in Palm Beach or in the Virgin Islands? 24 A. I'm sorry, can you just repeat the 25 question? Page 27 Page 29 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 2 Q. Have you ever seen anyone give 3 Mr. Epstein a massage anywhere other than in I5 Q. Did you provide massages to 4 5 his home in Palm Beach or in the Virgin Islands? 6 Mr. Epstein? 6 A. No, I can't think of anyplace. 7 A. No. 7 Q. Have you ever seen anyone give 8 Q. What? 8 Mr. Epstein a massage when Mr. Epstein was 9 A. No. 9 not clothed? 10 Q. Were you ever present when anyone 10 A. Sorry, can you repeat the question? 11 provided a massage to Mr. Epstein? 11 Q. Have you ever seen anyone give 12 MR. PAGLIUCA: Object to the form 12 Mr. Epstein a massage when Mr. Epstein was 13 and foundation. 13 not clothed? 14 A. I have seen people give Mr. Epstein 14 A. I think when Mr. Epstein received 15 massages. I have seen him on a massage 15 massages, he never had clothes on. 16 table. I have seen that. 16 Q. Who did you see give Mr. Epstein a 17 Q. Have you seen someone other than 17 massage? 18 yourself give Mr. Epstein a massage at his 18 A. I can't recall the "whos" because I 19 home in New York? 19 don't really remember, but I have seen him 20 A. I can't recall seeing him in the 20 receive massages from professional adult 21 massage room in New York, no. 21 masseuses that I have seen him receive 22 Q. I'm not asking whether you recall 22 massages. 23 seeing him in the massage room in New York. 23 Q. When you say professional adult 24 I'm asking you whether you have ever seen 24 masseuses, what are you referring to? 25 someone other than yourself give Mr. Epstein 25 A. I just want to be sure that we 8 (Pages 26 to 29) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 10 of 73 Confidential Page 30 Page 32 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 understand that the times I have seen him 2 as professional massages, you were clothed or 3 receive a massage it's been by somebody who 3 unclothed? 4 is an adult, clearly an older person. I 4 A. Unclothed. 5 don't know if they're professional, but an 5 Q. Completely unclothed? 6 older person appearing to be a professional 6 A. Typically when you receive a 7 masseuse. 7 massage you are not clothed, so I was 8 Q. What led you to believe that the 8 unclothed, as is the norm in a massage 9 person giving the massage was a professional 9 situation. 10 masseuse? 10 Q. That is, you didn't have any 11 A. Because the massages that I 11 clothes on, is that the case? 12 witnessed looked professional. I don't know 12 A. Generally, what happens is you are 13 how to -- I'm defining it as opposed to the 13 not wearing any clothes and you have a towel 14 ones from where people ask me inappropriate 14 or sheet that covers you while you are 15 questions, I couldn't answer, but these are 15 receiving the massage, so I would be covered 16 people who would be clothed giving a 16 always, but underneath the sheet or towel, I 17 professional massage, it appeared to be a 17 would not be wearing any clothing. 18 professional massage, as opposed to any other 18 Q. Are you saying that the massage was 19 type of massage. 19 through the sheet? 20 Q. Have you ever had what you refer to 20 A. Well, in some instances, yes. 21 as a professional massage? 21 Q. It is your testimony that when you 22 A. I have. 22 received what you referred to as professional 23 Q. Have you ever had what you refer to 23 massages, the masseuse didn't touch your 24 as a professional massage in any of Mr. 24 skin, only touched the sheet? 25 Epstein's homes? 25 MR. PAGLIUCA: Object to the form Page 31 Page 33 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 A. I have. 2 and foundation. 3 Q. Did you ever have what you refer to 3 A. I didn't say that. I said in some 4 as a professional massage in Mr. Epstein's 4 instances, some massages are where you don't 5 home in New York? 5 touch the skin, so I have received massages 6 A. I don't recall, but I think I have, 6 where I don't get touched, especially if it's 7 but I don't recall. I must have, but I don't 7 just pressure, so it's through a sheet, but I 8 recall. 8 have also received massages where you are 9 Q. Did you ever have what you refer to 9 touched and the sheet is just there for 10 as a professional massage in Mr. Epstein's 10 modesty. 11 home in Palm Beach? 11 Q. Have you ever received what you 12 A. I did. 12 referred to as a professional massage when 13 Q. Did you ever have what you refer to 13 anyone else was in the room other than the 14 as a professional massage in Mr. Epstein's 14 person that you are referring to as a 15 home in New Mexico? 15 professional masseuse? 16 A. I did. 16 MR. PAGLIUCA: Object to the form 17 Q. Did you ever have what you refer to 17 and foundation. 18 as a professional massage in Mr. Epstein's 18 A. Can you repeat the question, 19 home in Paris? 19 please? 20 A. I did. 20 Q. Have you ever received a massage 21 Q. Did you ever have what you refer to 21 when anyone was in the room other than the 22 as a professional massage in the Virgin 22 person that you refer to as a professional 23 Islands? 23 masseuse? 24 A. I did. 24 MR. PAGLIUCA: Same objection. 25 Q. When you had what you referred to 25 A. I am entirely possible that in the 9 (Pages 30 to 33) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 11 of 73 Confidential Page 34 Page 36 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 course of receiving a massage someone would 2 home to give him a massage, other than 3 come in and sit and chat to me while I was 3 someone who had previously given you a 4 getting a massage, a friend would come in. 4 massage? 5 That has happened. 5 A. No, I don't think so. No, I don't 6 Q. Do you recall that happening? 6 think so. 7 A. Not with specificity, I can't think 7 Q. Is it your testimony that everyone 8 of it actually, but I know that I've had 8 that you arranged to come to Mr. Epstein's 9 friends come in and we've talked and as I got 9 home to give Mr. Epstein a massage was 10 a massage, that has happened. 10 somebody you had already had a massage from? 11 Q. Have you ever received a massage 11 A. No, that is not my testimony. I 12 when Mr. Epstein was present? 12 don't recall -- there were definitely 13 A. He has entered the room and gave me 13 instances where I had a massage and -- so 14 a message or asked me a question, that has 14 what you are asking me was if anyone came to 15 happened. 15 the house to give him a massage that I had 16 Q. Have you ever received a massage 16 not had a massage from myself? 17 when Mr. Epstein was in the room other than 17 Q. It's a little different than that. 18 just to come in to give you a message or ask 18 A. Okay. 19 you a question? 19 Q. You've testified that you arranged 20 MR. PAGLIUCA: Object to the form 20 for some people to come to Mr. Epstein's home 21 and foundation. 21 to give him a massage, correct? 22 A. Not that I recall. 22 A. Yes. 23 Q. Did you ever participate in 23 Q. And at one point, I thought you had 24 arranging for anyone to give Mr. Epstein a 24 testified that before you arranged to have 25 massage? 25 people come to give Mr. Epstein a massage, Page 35 Page 37 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 A. Part of my duties and my job -- can 2 you had -- you didn't use the word tested 3 you repeat the question so I understand, and 3 them out, but that you had previously gotten 4 I give you the right answer exactly. 4 them to give you a massage so that you could 5 Q. Did you ever participate in 5 see how good they were, is that fair to say? 6 arranging for anyone to give Mr. Epstein a 6 A. If I thought they were -- if I 7 massage? 7 thought it was a good massage, yes, that is 8 A. Part of my professional 8 my testimony. 9 responsibilities, I did, and I've testified 9 Q. What I had thought, and what I'm 10 previously, go to spas and other professional 10 now asking you is that everyone who you 11 areas and received massages from people in 11 arranged to come to Mr. Epstein's home to 12 these places, and if I felt that person was 12 give him a massage was somebody who you had 13 good or I had had a good massage, I had asked 13 already had a massage from, is that fair? 14 if they do home visits. 14 A. Typically, yes, but that wasn't 15 In that capacity, I had, people did 15 exclusively. So I know that friends of mine, 16 come to the house in that capacity, that I 16 for instance, would have a masseuse or 17 thought were good. 17 masseur that they thought was very good, and 18 Q. Did you ever arrange for anyone to 18 they said this is a very good person. 19 give Mr. Epstein a massage or to come to his 19 So it is possible, and I'm pretty 20 home to give him a massage, other than 20 sure sometimes on recommendations of other 21 someone who had previously given you a 21 people, that without me having a massage from 22 massage? 22 them, that they may have come to the house. 23 A. Sorry, can you repeat the question? 23 So I could not testify that every single 24 Q. Did you ever arrange for anyone to 24 person that came to the house I received a 25 give Mr. Epstein a massage or to come to his 25 massage from, because that would not be true. 10 (Pages 34 to 37) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 12 of 73 Confidential Page 38 Page 40 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 Q. Was every person who you arranged 2 A. I know what the allegations are, 3 to come to Mr. Epstein's house to give a 3 and I am aware of those, but as to my actual 4 massage someone who either you had already 4 knowledge of somebody under the age of 21, I 5 had a massage from or you had a friend who 5 can't say that I know, I can't think of 6 recommended them as a good professional 6 anybody. I know Virginia has obviously made 7 masseuse? 7 those claims and she was 17 when he met her, 8 MR. PAGLIUCA: Object to the form 8 but other than her, I cannot think of 9 and foundation. 9 anybody. 10 A. Typically, that is how that would 10 Q. Insofar as you are aware, did 11 work. 11 Virginia ever give Mr. Epstein a massage? 12 Q. Was there ever anyone who you 12 A. I know she said she did and I 13 arranged to come to Mr. Epstein's house to 13 believe she may have, but I don't ever see 14 give him a massage, someone who you had not 14 her giving him a massage, so I can't say. 15 previously gotten a massage from yourself or 15 Q. Leaving aside any information that 16 received a recommendation from one of your 16 you have that has come from Virginia in the 17 friends that it was a good professional 17 last decade? 18 masseuse? 18 A. Right. 19 MR. PAGLIUCA: Object to the form 19 Q. Going back to the time when 20 and foundation. 20 Virginia was less than 21, at that period of 21 A. I cannot think of anyone that would 21 time, did you believe that Virginia was 22 fit that category. 22 giving Mr. Epstein massages? 23 Q. You made a point in a previous 23 A. I do think she was giving him 24 answer of referring to people as adult 24 massages. 25 masseuses. Do you recall that? 25 Q. Is it your testimony that the only Page 39 Page 41 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 A. I do. 2 female that you had any reason to believe was 3 Q. When you refer to someone as an 3 under 21 who was giving Mr. Epstein massages 4 adult masseuse, what are you referring to? 4 was Virginia? 5 A. I think everybody in this room is 5 MR. PAGLIUCA: Object to the form 6 an adult. 6 and foundation. 7 Q. I don't necessarily disagree with 7 A. First of all, I didn't know how old 8 that, but what I'm asking you, since I can't 8 Virginia was, so other than Virginia, so I 9 carry all these people with me every time 9 can't say, but other than -- I was not aware 10 somebody reads this transcript, is what do 10 of anybody else, no. 11 you mean by an adult? 11 Q. You first met Virginia when? 12 A. Well, I think an adult is somebody 12 A. I don't know. 13 who looks older and professional and is 13 Q. Approximately? 14 someone who has lived some life and looks 14 A. I believe it was in 2000, but now 15 like any one of us in this room do, some a 15 I'm going off the knowledge that I have, not 16 little older and some a little younger. 16 from memory, so I met her the end of 2000 17 Q. You are aware that there are 17 apparently. 18 assertions that Mr. Epstein had massages from 18 Q. And when you met Virginia in 2000, 19 females under the age of 21? 19 how old did you think she was? 20 A. I am aware of that. 20 MR. PAGLIUCA: Object to the form 21 Q. Insofar as you are aware, did 21 and foundation. 22 Mr. Epstein ever have a massage from anyone 22 A. I didn't think about how old she 23 under the age of 21? 23 was. I don't recall the actual meeting of 24 MR. PAGLIUCA: Object to the form 24 Virginia, so I can't say, but I think she was 25 and foundation. 25 at least, I thought she was a professional 11 (Pages 38 to 41) MAGNA9 LEGAL SERVICES  Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 13 of 73 Confidential Page 42 Page 44 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 masseuse as far as I can recall today, so 2 thought. I really don't recall her, so it's 3 that would have made her, I thought that 3 hard for me to testify what I thought about 4 would have made her, to work in a spa, I 4 her age at the time. 5 didn't think about, and I, I thought she 5 Q. Was Virginia, in the period of 6 appeared to be a professional masseuse. 6 around 2000, the youngest person that, as you 7 Q. Remember questions a while ago 7 understood it, was giving Mr. Epstein 8 where you made a big point about people being 8 massages? 9 adult masseuses? 9 MR. PAGLIUCA: Object to the form 10 A. Right, yeah. 10 and foundation. 11 Q. When you met Virginia for the first 11 A. Again, I can't testify to her age, 12 time -- 12 but everybody else that I can recall seemed 13 A. Right. 13 to be again, like I would say, adults. 14 Q. -- did you think she was an adult 14 Q. You didn't think Virginia was an 15 masseuse, as you use that term? 15 adult, did you? 16 A. I don't recall actually meeting 16 MR. PAGLIUCA: Object to the form 17 Virginia at the time, and in fact, were it 17 and foundation. 18 not for this case, I'm not sure I would 18 A. Like I said, I don't recall her. I 19 recall her at all. 19 don't recall thinking about -- my memory is 20 Q. But you do recall knowing Virginia? 20 of adults giving Jeffrey massages, and as I 21 A. I do, yes. 21 don't really remember Virginia around that 22 Q. You do recall knowing that Virginia 22 time, I don't know what I think. 23 was giving Mr. Epstein massages, correct? 23 Q. You do remember Virginia, about 24 MR. PAGLIUCA: Object to the form 24 that time back in the 2000s, giving 25 and foundation. 25 Mr. Epstein massages? Page 43 Page 45 1 G. Maxwell - Confidential 1 G. Maxwell - Confidential 2 A. I believe she was, but I can't say 2 MR. PAGLIUCA: Object to the form 3 for sure. 3 and foundation. 4 Q. Why do you believe Virginia was 4 A. I barely remember her at all. 5 giving Mr. Epstein massages? 5 Q. Whether you barely remember her or 6 A. Today, because -- but back then. 6 not, you do remember that back in the period 7 Q. Back then? 7 around 2000, Virginia was giving Mr. Epstein 8 A. Because at some point she would 8 massages, right? 9 have been going to the massage room to give 9 MR. PAGLIUCA: Objection to form 10 massages.