EFTA01306406.pdf

FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 1:2 RECEIVEDg NYSCEF: 03/05/2020 Pa e April 9, 2019 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X SHELDON BARR and THOMAS GARDNER, Plaintiffs, -against- CITY OF NEW YORK and 116 EAST 65TH STREET, LLC, Defendants, INDEX NO.: 159225/2010 X 535 Fifth Avenue New York, New York April 9, 2019 10:07 a.m. EXAMINATION BEFORE TRIAL of the Defendant, 116 EAST 65TH STREET, LLC, by GHISLAINE MAXWELL, in the above-entitied action, held at the above time and place, taken before a Notary Public of the State of New York, pursuant to Order and Stipulations between Counsel. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323955 EFTA_0011 96640 EFTA01306406 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEI/NfblY*CEF: 03/05/2020 April 9, 2019 1 2 2 APPEARANCE S: 3 THE LAW OFFICE OF JOSEPH FALLEK 4 Attorney for Plaintiffs One Battery Park Plaza, 32nd Floor 5 New York, New York 10004 6 BY: LARRY FALLEK, ESQ. 7 8 CUOMO, LLC. Attorney for Defendant 116 EAST 65TH STREET, LLC. 200 Old Country Road, Suite 2 South Mineola, New York 11501 11 BY: MATTHEW CUOMO, ESQ. 12 FILE NO.: AIGPRIV 17007 12 IA 1( 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-676-0166 SDNY_GM_00323956 EFTA_00196641 EFTA01306407 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVIRpg@YBFEF: 03/05/2020 April 9, 2019 1 3 2 STIPULATIONS 3 IT IS HEREBY STIPULATED AND AGREED by and 4 between(among) counsel for the respective parties 5 hereto, that: 6 7 All rights provided by the C.P.L.R., 8 including the right to object to any question, 9 except as to form, or to move to strike any ID testimony at this(these) examinations(s), are 11 reserved, and, in addition, the failure to object to 12 any question or to move to strike any testimony at 13 :his(these) examination(s) shall not be a bar or 14 waiver to make such motion at, and is reserved for lb the trial of this action; 16 17 IT IS FURTHER STIPULATED AND AGREED by and 18 between(among) counsel for the respective parties 19 hereto, that this(these) examinations(s) may be 20 sworn to by the witness(es) being examined, before a 21 Notary Public other than the Notary Public before 22 whom thisithese) examination(s) was:were) begun; but 23 the failure to do so, or to return the original of 24 this(these) examinations(s) to counsel, shall not be 25 deemed a waiver of the rights provided by DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323957 EFTA 00196642 EFTA01306408 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEINWY4CEF: 03/05/2020 April 9, 2019 4 2 ST/PULATIONS (Cont'd) 3 Rules 3116 and 3117 of the C.P.L.R., and shall be 4 controlled thereby; 5 6 IT IS FURTHER STIPULATED AND AGREED by and 7 between(among) counsel for the respective parties 8 hereto, that this(these) examinations(s) may be 9 utilized for all purposes as provided by the 10 C.P.L.R; 11 12 IT IS FURTHER STIPULATED AND AGREED by and 13 between(among) counsel for the respective parties 14 hereto, that the filing and certification of the 15 original of this(these) examination(s) shall be and 16 the same hereby are waived; 17 18 IT IS FURTHER STIPULATED AND AGREED by and 19 between(among) counsel for the respective parties 20 hereto, that a copy of the within examination(s) 21 shall be furnished to counsel representing the 22 witness(es) testifying, without charge. 23 24 IT IS FURTHER STIPULATED AND AGREED by and 25 between(among) counsel for the respective parties DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323958 EFTA_00I96643 EFTA01306409 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVFERg@Y.%pEF: 03/05/2020 April 9, 2019 5 2 STI PULATIONS (Conttd) 3 hereto, that all rights provided by the C.P.L.R., 4 and Part 221 of the Uniform Rules for the Conduct of 5 Depositions, including the right to object to any 6 question, except as to form, or to move to strike 7 any testimony at this examination is reserved; and 8 in addition, the failure to object to any question 9 or to move to strike any testimony at this 10 examination shall not be a bar or waiver to make 11 such motion at, and is reserved to, the trial of 12 this action. 13 14 15 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323959 EFTA_001196644 EFTA01306410 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIXWITsCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 GHISLAINE M A X W E L L, called as a 3 witness, having been first duly sworn by a Notary Public of the State of New York, was examined and testified as follows: 6 EXAMINATION BY MR. FALLEK: 8 Q. Please state your name for the record. 9 A. Ghislaine Maxwell. 10 Q. Please state your address for the record. 11 A. 44 Kinnerton Street, London, England 12 SW183X. 13 MR. FALLEK: Good morning, Ms. Maxwell. My 14 name is Larry Fallek. I represent the 15 plaintiffs in this action, Sheldon Barr and 16 Thomas Gardner. 17 I will be asking you a series of questions 18 about an accident that occurred back on 19 September 9, 2015. Many of the questions are 20 going to involve your ownership. When I say, 21 "your ownership," I am referring to the 22 ownership of 116 East 65th Street in 23 Manhattan. 24 THE WITNESS: Okay. 25 MR. FALLEK: Before we start I have a few DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323960 EFTA_00I96645 EFTA01306411 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIligogNYSCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 basic rules I want to discuss with you. Please 3 make all your responses verbally. The Court Reporter can't take down a shake or nod of cite b head. Like you are doing right now. THE WITNESS: Of course. 7 MR. FALLEK: Please say yes or no. 6 THE WITNESS: Yes. MR. FALLEK: And try not to shrug your 10 shoulders or anything like that. Just make all 11 your response verbally. 12 THE WITNESS: I shall. 13 MR. FALLEK: Please let me finish my entire 14 question before you give an answer. The Court 15 Reporter cannot take us both down speaking a - 16 the same time. 17 Q. Is that agreeable? 18 A. Yes. 19 MR. FALLEK: It's important that you stop 20 me if you don't understand a question. If you 21 do give an answer, I will assume that you 22 understand my question. 23 0. Is that understood? 24 A. Yes. 25 0. The address that you just gave the Cot a DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323961 EFTA_00I96646 EFTA01306412 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIWOYfICEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Reporter, how long have you lived there? 3 A. '92, '93. 4 Q. Is that your primary residence at this 5 time? 6 A. No. It's just a home that I have. 7 Q. How many homes do you own back in September 8 of 2015? 9 A. Two. 10 Q. Where are those homes? 11 A. 116 East 65th Street and the one in London. 12 Q. When you say, "the one in London," you are 13 referring to the address that you just gave? 14 A. Yes. 15 Q. Is that a private home? 16 A. Yes. 17 Q. Is that home owned by you individually or 18 some other form? 19 A. It's owned by me. 20 Q. Is your name on the deed to that property 21 or the title of the property? 22 A. It was back then. I kind of -- it was up 23 until recently. I don't know. I can't remember 24 what it is now, if I changed it or not. 25 Q. Sack in September of 2015, did you or any DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323962 EFTA_00I96647 EFTA01306413 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVEWY§CEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 of your entities or companies own any other homes? 3 A. No. 4 Q. What was your primary residence back in 5 September of 2015? 6 A. 116 East 65th Street. 7 Q. Can you tell me how much time you spent 8 there, say, back in 2015 from January 1st through September 9, 2015? 10 A. A lot of time. I lived there. That's my 11 primary residence. 12 Q. Did you travel back and forth between 13 London and New York? 14 A. Extensively at. all the time. I just Gen': 15 go to London. I travel all the time to a lot of 16 different places. 17 Q. For what purposes do you travel, business, 18 pleasure, or something else? 19 A. I do business. But, it was also I work 20 on work for a not-for-profit. And I do a lot 21 of time doing conferences and a lot of speeches. 22 Q. I'm just talking about the time period of 23 January 1, 2015 through September 9, 2015. 24 Would that be true with regard to that time 25 period? DEITZ Court Reporting... A Lox tas Company 800-678-0166 SDNY_GM_00323963 EFTA_00I96648 EFTA01306414 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECElfiribNitCEF: 03/05/2020 April 9, 2019 1 GHISLA1NE MAXWELL 2 A. Correct. 3 Q. Where were you born? 4 A. Paris, France. 5 Q. What is your date of birth? 6 A. The 25th of December 1961. 7 Q. Are you a U.S. Citizen at this time? 8 A. Yes. 9 Q. When did you become a U.S. Citizen? 10 A. I don't recall. But it was some time in 11 the late '90s, mid '90s. I'm not sure. I don't 12 remember. 13 Q. Are you a citizen of any other country? 14 A. Yes 15 Q. What other countries? 16 A. France and England. 17 Q. Sorry, France and? 18 A. England. 19 Q. Are you a citizen or you are a green card 20 holder? 21 A. I'm a citizen. 22 Q. Can you tell me about your educational 23 background? What is the highest level of education 24 that you have? 25 A. I have a master's. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323964 EFTA_00I 96649 EFTA01306415 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4j INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIyne NiiCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. In what? 3 A. French and history from Oxford. It's a BA 4 MA. So when you go to oxford and you get a 5 bachelor's and some time passes and it turns into a 6 master's. 7 Q. What is the BA in? 8 A. French and history. 9 Q. It's a combined degree? IC A. Double honors degree in French and history. 11 Q. Do you have any other degrees? 12 A. No. 13 Q. Do you have any professional degrees or 14 licenses? 15 A. I do. 16 Q. In what? 17 A. I'm a registered emergency technician, 18 first responder, EMT. I'm a helicopter pilot. 19 Q. Sorry? 20 A. Helicopter pilot. 21 Q. Is your certification as an EMT in the 22 United States or another country? 23 A. In the U.S. 24 Q. You didn't offer any medical assistance to 25 :he Plaintiff in this action? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323965 EFTA_00I96650 EFTA01306416 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 1:2 RECEMyeNyICEF: 03/05/2020 April 9, 2C19 1 GHISLAINE MAXWELL 2 A. No. 3 Q. Are you presently employed? 4 A. No. S 0. Are you self-employed? A. No. Q. What was the last job that you had? A. The last job I had was at Ellmax. 9 E-L-L-M-A-X. 10 Q. What. is Ellmax? 11 A. It's no longer in existence. 12 Q. What was it? 13 A. It was a company I started to advise other 14 businesses on board placement, placing board of 15 directors, and any other questions they might have, 16 conferences, locations for conferences, speakers dt. 17 conferences. 18 Q. What is the primary business? Is it 19 Ellmax, LLC.? 20 A. I think so. 21 Q. Is that a Florida Limited Liability 22 Company? 23 A. Whatever paperwork I have. I don't recall. 24 Whatever it says on the paperwork. 25 MR. FALLEK: I'm going to show you three DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323966 EFTA_00I96651 EFTA01306417 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyireeNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 documents that we will have marked as Plaintiff's Exhibit 1, 2, 3. 4 (Whereupon, the document dated 9-18-14, 5 was received and marked as Plaintiff's Exhibit 1 6 for identification, as of this date, by the 7 reporter.) B (Whereupon, the document dated 2-23-15, 9 was received and marked as Plaintiff's Exhibit 2 10 for identification, as of this date, by the 11 reporter.) 12 (Whereupon, the document dated 3-22-16, 13 was received and marked as Plaintiff's Exhibit 3 14 for identification, as of this date, by the 15 reporter.) 16 MR. FALLEK: I'm directing your attention 17 to the document we just marked as Plaintiff's 18 Exhibit 1 for identification. 19 Q. Do you recognize this document to be the 20 2014 Florida Limited Liability Annual Report for 21 Illmax, LLC.? 22 A. I have not seen this document before so I 23 can't say that. 24 Q. Just take a look at it. 25 A. I'm looking at it, but it's the first time DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323967 EFTA )0196652 EFTA01306418 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbil INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiPVEal-De NYECEF: 03/05/2020 1 April 9, 2019 1 GHISLAINE MAXWELL 2 I've seen this. 3 Q. Did you form Ellmax, LLC.? 4 A. I did. 5 Q. Is it your company? 6 A. IL is. It was. .7 0. When was it formed? 8 A. I think 2010 or '11. 9 Q. Was it formed in Florida? 10 A. I guess. I'm sorry, I just don't recall. 11 Q. Could you tell me what the business purpose 12 of Ellmax, LLC. is? 13 A. It was a vehicle for me to be able to 14 advise companies on board of directors and to help 15 with companies for conferences and speakers for 16 their conferences. 17 Q. Board of directors of what type of 18 companies are you advising people on? 19 A. Mostly technology businesses, because I 20 know a lot of people in technology. It could be in 21 anything as a board of directors are needed in any 22 type of company. And people of good character and 23 outstanding abilities in business are always needed. 24 And I, fortunately, have a lot of friends and people 25 in that area that I will be able to place people in DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323968 EFTA_00I96653 EFTA01306419 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEigyeNlICEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 those type of companies. 3 Q. Was the principal place of business of 4 Ellmax, LLC. at 116A East 65th Street, New York, New 5 York? 6 A. It wasn't that specific. It was wherever I 7 was. Everything that is in my head is my contact, 8 my ideas. 9 Q. Specifically the document in front of you, 10 when you formed it, did you indicate that the 11 principal place of business was 116 East 65th 12 Street, New York, New York? 13 A. I think it was just filed there. It would 14 be easier for me other than any other reason. 15 0. Did you sign the documents for the limited 16 liability company known as Ellmax, LLC.? 17 A. I'm sure I did with my lawyers. There was 18 no reason other than as an address of convenience. 19 MR. FALLEK: Move to strike the 20 nonresponsive portion. 21 THE WITNESS: I'm not trying 22 NR. FALLEK: Just try focus on the question 23 that I'm asking you. 24 THE WITNESS: I'm not trying to be 25 evasive. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00323969 EFTA_00196654 EFTA01306420 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECELyneNWEF: 03/05/2020 Apri l 9, 2019 GHISLAINE MAXWELL 2 Q. Who is A. She's my personal assistant. 4 Q. How long was she your personal assistant? 5 A. More than ten years. 6 Q. More than ten years from today? A. No. She doesn't work for me anymore. 8 Q. When did you start working for you? 9 A. Again, some time in 2001, 2002. Something 10 like that. 11 Q. Was she your personal assistant for the 12 next ten years? 13 A. Yeah. 14 Q. Was she paid by Ellmax, LLC.? 15 A. I paid her myself. 16 Q. Did you pay her out of a different company 17 or different funds or what source? 18 A. I don't recall where I paid her from 19 exactly. She was not an employee of -- I was the 20 only person that did any work for Ellmax. She was 21 my personal assistant. She was able -- she would do 22 anything I would ask her to do as regards to my 23 travel, whatever. But she was -- she couldn't help 24 me with Ellmax. She didn't know people to place 25 them on board. If I directed her to get me on A DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323910 EFTA_00I96655 EFTA01306421 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIMeNISFEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 flight or something that may have been in relation 3 to business opportunity, she would do that. Q. What is her current address? S A. 1 don't know. 6 Q. Do you know what state she lives in? A. I think she's in Detroit somewhere. Q. Back in 2016, did she live at 116 East 65th 9 Street, New York, New York? 10 A. No. 11 Q. Where did she live in 2016? 12 A. Somewhere in New Jersey. 13 MR. FALLER: Directing your attention to 14 Plaintiff's Exhibit 2 for identification. 15 Q. Is that the 2015 Florida Limited Liability 16 Company for Ellmax, LLC.? 17 A. Again, I have not seen this before. I have 18 to take -- I haven't seen this before. So I'm 19 assuming that's what it is. 20 Q. Were regular annual reports filed by 21 Ellmax, LLC.? 22 A. Again, that would have been my accountant, 23 I would assume, would have a list of what is 24 expected or legally. 25 Q. Who was your accountant back then? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323971 EFTA_00I 96656 EFTA01306422 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECED F/SO aqe NYSCEF: 03/05/2020 18 April 9, 2019 GHISLAINE MAXWELL 2 A. I am sorry, I don't recall the name at this 3 moment. 4 Q. What was the name of the company that you 5 worked for? 6 A. I don't recall. I am sorry. 7 Q. Was he in New York or Florida? 8 A. In New York, I believe. 9 Q. Was there a reason you chose a Florida 10 Limited Liability Company for Ellmax, LLC.? 11 A. I don't know why. I don't remember. 12 Q. Were you also a Florida resident back in 13 2016? 14 A. I lived in Florida at certain times since I 15 moved to the states. 16 Q. What is your address in Florida? 17 A. I lived in a number of different places in 18 Florida. 19 Q. Do you own real estate in Florida? 20 A. No. 21 Q. At any point did you maintain a residence 22 in Florida? 23 A. I've never owned a home in Florida. 24 Q. Did you rent the same residence in Florida? 25 A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323972 EFTA_00I96657 EFTA01306423 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIffeeNiiFEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. How many months of the year, let's say, it 3 2016 did you reside in Florida? 4 A. Probably none. 5 Q. How much time did you spend in Florida .L:1 6 2016? 7 A. Probably, I don't know, less than -- I S don't know. A few weeks. Two weeks, three weeks. 9 Q. What about in 2015? 10 A. I don't remember the dales. Maybe the 11 same. 12 Q. The principal place of business in 2015 is 13 still listed as 116A East 65th Street, New York, New 14 York. 15 A. That would have all been the address for 16 convenience. 17 Q. That address was never changed was it? 18 A. I don't believe so. 19 Q• Was the address of Ellmax always the same 20 from the time it was formed until up the time you 21 say you dissolved it? 22 A. As far as I can recall, yes. 23 MR. FALLEK: 1 am directing your attention 24 to Plaintiff's Exhibit 3 for identification. 25 Q. Do you recognize this document? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323973 EFTA_00I96658 EFTA01306424 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIg8eNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Sorry. 3 Q. Plaintiff's 3 for identification, do you 4 recognize this to be the 2016 Florida Limited 5 Liability Company Annual Report for Ellmax, LLC.? 6 A. Again, I have never seen this. I will just 7 take your word that that's what that is. 8 Q. In 2016, was the principal place of 9 business for Ellmax, LLC. also listed as 116 East 10 65th Street, New York, New York? 11 A. Again, that was the address of convenience. 12 The business is wherever I am, but yes. 13 MR. FALLEK: Move to strike the 14 nonresponsive portion of the answer. 15 Q. Did Ellmax, LLC. ever have a different 16 principal place of business? 17 A. I don't believe I had any other address of 18 convenience than the one it has listed. 19 MR. FALLEK: Move to strike as 20 nonresponsive. 21 Q. Is the answer no? 22 A. No. 23 Q. No it never had any other principal place 24 of business? 25 A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323974 EFTA_00196659 EFTA01306425 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyafliCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. What were the assets of Ellmax, LLC.? 3 A. it didn't have any assets. 4 Q. Who were the members of the limited 5 liability company? 6 A. I believe I was the sole member. 7 Q. Did Ellmax, LLC. have any employees? 8 A. No. Q. I believe you said the last job you had was 10 for Ellmax, LLC.? 11 A. Last work that I did as you asked. 12 Q. Before you worked for Ellmax, LLC., whom do 13 you work for? 14 A. I was unemployed. 15 Q. During what period of time was that? 16 A. I believe around 2000 -- about 2009 or '08. 17 Q• When did you first move to the United 18 States to live here continuously? 19 A. 1991. 20 Q. Where did you live in 1991? 21 A. I was traveling around the states. 22 Q. Was 116 East 65th Street, New York, New 23 York, the first residence that you had in the United 24 States? 25 MR. FALLER: You seemed confused. I will DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323975 ER-Ai/0196660 EFTA01306426 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyneNWEF: 03/05/2020 April 9, 2019 1 GH:SLAINE MAXWELL 2 ask it a different way. 3 Q. Where was the first place you lived in the 4 United States? 5 A. I rented. 6 Q. Where did you rent? 7 A. I rented a place on 59th and Seventh. 8 Q• Did there come a time period where you 9 purchased a residence? 10 A. Yes. 11 Q. When was that? 12 A. When I purchased 116, I believe, in 2000. 13 Q. Before 116 was purchased, did you form 116 14 East 65th Street, LLC.? 15 A. No. I don't believe so, no. 16 MR. FALLEK: Could we have this marked as 17 Plaintiff's Exhibit 4 for identification. 18 (Whereupon, the document dated 4/5/19, was 19 received and marked as Plaintiff's Exhibit 4 for 2C identification, as of this date, by the 21 reporter.) 22 Q. Before we get to this document. Was there 23 a time period in which =MI lived in 24 Manhattan? 25 A. I don't know. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323976 EFTA_00196661 EFTA01306427 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEM eNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. You said she was your personal assistant. 3 A. I did. 4 (2• Was that a remote job or did she live with 5 you or lived nearby? 6 A. She never lived in my home. I can't 7 recall. Wherever she lived I don't know. I'm 8 sorry. 9 Q. Was it a full-time or part-time job? 10 A. It was full-time. 11 Q. How would you communicate with her? 12 A. Via, email, text, or phone. 13 Q. During what time period, if any, did she 14 live in New York? 15 A. I don't know if she lived in New York. She 16 worked for me, and she turned up for work for me. 17 But, I don't know where she lived. 10 Q. Did you have somebody else, a different 19 personal assistant for you, in Manhattan? 20 A. No. 21 MR. FALLEK: I'm going to show you what was 22 marked as Plaintiff's Exhibit 4 for 23 identification. I ask you to take a look at 24 that document. 25 Q. Do you recognize this document to be a DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323977 EFTA 00196662 EFTA01306428 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 24 April 9, 2019 GHISLAINE MAXWELL 2 document from the New York State Department of State 3 regarding 116 East 65th Street, LLC.? 4 A. I have never seen this document before. 5 Q. Could you please take a look at it. MR. CUOMO: I think she has. 7 A. I've looked at it. 8 Q. Did you form 116 East 65th Street, LLC. 9 A. Yes. 10 Q. When was it formed? 11 A. Some time in 2000. 12 Q. Is that prior to the time that 116 East 13 65th Street was purchased? 14 A. I don't know the timing of it when it was 15 purchased. I don't know when the time was for the 16 creation of it and the purchase of the house. I'm 17 sorry. 18 Q. Is 116 East 65th Street a limited liability 19 company? 20 A. I believe so. 21 Q. Is it a New York Limited Liability Company? 22 A. I don't remember where it is limited. It 23 says, New York. 24 Q. Who are the members of that LLC? 25 A. I believe I'm the sole member. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323978 EFTA_00196663 EFTA01306429 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 25 April 9, 2019 GHISLAINE MAXWELL Q. Was there ever any other members? A. I don't believe so. 4 Q. Could you tell me who Darren Indyke, Esq. 5 at 475 West Avenue, New York, New York is? Could 6 you tell me who he is? 7 A. He is a lawyer. 8 Q. What is his connection with the LLC? 9 A. He helped create it. 10 Q. Did you hire him to create it? 11 A. I don't recall how it went down exactly. 12 How he came to do it. But, he was the lawyer