EFTA00065870.pdf

WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIVED NYSCEF: 03/05/2020 Page 1 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 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, LLC, by GHISLAINE MAXWELL, in the above-entitled 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 EFTA00065870 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEINOIY2CEF: 03/05/2020 April 9, 2019 2 APPEARANCE S: 3 THE LAW OFFICE OF JOSEPH FALLEK Attorney for Plaintiffs New York, New York 10004 BY: LARRY FALLEK, ESQ. CUOMO, LLC. Attorney for Defendant 10 Mineola, New York 11501 11 BY: MATTHEW CUOMO, ESQ. 12 FILE NO.: AIGPRIV 17007 13 14 15 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065871 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf. INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIMRDINYSFEF: 03/05/2020 April 9, 2019 1 3 2 STI PULATIONS 3 IT IS HEREBY STIPULATED AND AGREED by and 4 between(among) counsel for the respective parties 5 hereto, that: 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 13 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 this(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 TT 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 this(these) 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 EFTA00065872 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEINIWY4CEF: 03/05/2020 April 9, 2019 ST/PULATIONS (Cont'd) Rules 3116 and 3117 of the C.P.L.R., and shall be controlled thereby; IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that this(these) examinations(s) may be 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 DETTZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065873 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIMNikuncEF: 03/05/2020 April 9, 2019 5 S T I P U L A T I O N S (Cont'd) hereto, that all rights provided by the C.P.L.R., and Part 221 of the Uniform Rules for the Conduct of Depositions, including the right to object to any question, except as to form, or to move to strike any testimony at this examination is reserved; and in addition, the failure to object to any question or to move to strike any testimony at this examination shall not be a bar or waiver to make such motion at, and is reserved to, the trial of this action. 13 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065874 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIWYeCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 G H I S L A I N E M A X W E L L, called as a 3 witness, having been first duly sworn by a Notary 4 Public of the State of New York, was examined and testified as follows: 6 EXAMINATION BY MR. £ALLEK: Q. Please state your name for the record. 9 A. Ghislaine Maxwell. 10 Q. Please state your address for the record. 11 A. 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 arr 20 going to involve your ownership. When I say, 21 "your ownership," I am referring to the 22 ownership of 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 EFTA00065875 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIWOYFEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL basic rules I want to discuss with you. Please make all your responses verbally. The Court Reporter can't take down a shake or nod of the head. Like you are doing right now. THE WITNESS: Of course. MR. FALLEK: Please say yes or no. THE WITNESS: Yes. MR. FALLEK: And try not to shrug your 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 Q. Is that understood? 24 A. Yes. 25 Q. The address that you just gave the Court DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065876 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIWY§CEF: 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? S A. Two. 10 Q. Where are those homes? 11 A. and the one in London. :2 Q. When yo..: 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. Back in September of 2015, did you or any 1 DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065877 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEINg,04YyCEF: 03/05/2020 Apri: 9, 2019 1 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. 7 Q. Can you tell me how much time you spent 8 there, say, back in 2015 from January 1st through 9 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 don't 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 Lexitas Company 800-678-0166 EFTA00065878 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEMpNy§CEF: 03/05/2020 April 9, 2019 GHISLAINE 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 7 0. 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 2C 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 EFTA00065879 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEM e 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? B A. French and history. 9 Q. It's a combined degree? 10 A. Double honors degree in French and history. 11 Q. Do you have any other degrees? 12 A. No. 13 0. 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 the Plaintiff in this action? DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065880 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIgyeNIICEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 A. No. 3 Q. Are you presently employed? 4 A. No. 5 Q. Are you self-employed? 6 A. No. 7 Q. What was the last job that you had? 8 A. The last job I had was at Ellmax. 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 at 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 thre- DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065881 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEigyeN/yEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL documents that we will have marked as Plaintiff's Exhibit 1, 2, 3. (Whereupon, the document dated 9-18-14, was received and marked as Plaintiff's Exhibit 1 for identification, as of this date, by the reporter.) (Whereupon, the document dated 2-23-15, 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 Ellmax, 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 EFTA00065882 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEMe NHCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWET,", 2 I've seen this. Q. Did you form Ellmax, LLC.? A. I did. 5 Q. Is it your company? 6 A. It is. It was. 7 Q. 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 EFTA00065883 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEM eNIIFEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 those type of companies. 3 Q. Was the principal place of business of 4 Ellmax, LLC. at 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 12 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 Q. 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 MR. 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 EFTA00065884 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIlyneNWEF: 03/05/2020 Apri l 9, 2019 GHISLAINE MAXWELL 2 Q• Who is A. my personal assistant. 4 Q. How long was ■ your personal assistant? A. More than ten years. 6 Q. More than ten years from today? 7 A. No. ■ doesn't work for me anymore. 8 Q. When did you start working for you? A. Again, some time in 2001, 2002. Something 10 like that. 11 Q. Was ■ your personal assistant for the 12 next ten years? 13 A. Yeah. 14 Q. Was paid by Ellmax, LLC.? 15 A. I paid myself. 16 Q. Did you pay out of a different company 17 or different funds or what source? 18 A. : don't recall where T paid from 19 exactly. was not an employee of -- I was the 20 only person that did any work for Ellmax. was 21 my personal assistant. was able -- would do 22 anything I would ask to do as regards to my 23 travel, whatever. But was -- couldn't help 24 me with Ellmax. didn't know people to place 25 them or. board. If I directed to get me on A DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065885 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEiykpN/CEF: 03/05/2020 April 9, 2019 1 GNISLAINE MAXWELL 2 flight or something that may have been in relation 3 to business opportunity, would do that. 4 Q. What is current address? 5 A. 1 don't know. 6 Q. Do you know what state III lives in? A. I think she's in somewhere. 8 Q. Back in 2016, did she live at 9 ■ New York, New York? IC A. No. 11 Q. Where did she live in 2016? 12 A. Somewhere in 13 MR. FALLEK: 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 LexiLas Company 800-678-0166 EFTA00065886 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIWygCEF: 03/05/2020 April 9, 2019 1 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 EFTA00065887 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEnikeNHFEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. How many months of the year, let's say, in 2016 did you reside in Florida? A. Probably none. Q. How much time did you spend in Florida in 2016? A. Probably, I don't know, less than -- I don't know. A few weeks. Two weeks, three weeks. Q. What about in 2015? A. I don't remember the dales. Maybe the same. Q. The principal place of business in 2015 is still listed as New York, New 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. FALLER: I 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 EFTA00065888 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P/t4 INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIOrgeWffEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Sorry. 3 Q. F1aintiff's 3 for identification, do you 4 recognize this to be the 2016 Florida Limited S Liability Company Annual Report for Ellmax, LLC.? A. Again, I have never seen this. I will just 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 10 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. 2] Q. Is the answer no? 22 A. No. 23 Q. No it never had any other principal place 24 of business? 25 A. No. DFTTZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065889 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIWge N ICEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. What were the assets of Ellmax, LLC. A. It didn't have any assets. Q. Who were the members of the limited liability company? A. I believe I was the sole member. Q. Did Ellmax, LLC. have any employees? 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 'OB. 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 New York, New 23 York, the first residence that you had in the United 24 States? 25 MR. FALLEK: You seemed confused. DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065890 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Phi) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEI PV P ED 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 ask it a different way. Q• Where was the first place you lived in the 4 United States? 5 A. I rented. 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 I believe, in 2000. 13 Q. Before ■was purchased, did you form 14 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 20 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 lived in 24 Manhattan? 25 A. I don't know. DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065891 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiygeNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. You said ■ was your personal assistant. 3 A. I did. 4 Q. Was that a remote job or did ■ live 5 you or lived nearby? 6 A. 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 12 A. Via, email, text, or phone. 13 Q. During what time period, if any, did ■ 14 live in New York? 15 A. I don't know if ■ lived in New York. 16 worked for me, and ■ turned up for work for me. 17 But, I don't know where ■ lived. 18 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 DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065892 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf. INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIVED NYSCEF: 03/05/2020 Page 24 April 9, 2019 GHISLAINE MAXWELL document from the New York State Department of State regarding LLC.? 4 A. I have never seen this document before. Q. Could you please take a look at it. 6 MR. CUOMO: I think she has. A. I've looked at it. 8 0. Did you form 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 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 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 EFTA00065893 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf INDEX NO. 159224/2016 NYSCEF DOC. NC. RECEIVED NX5CEF: 03/05/2020 Page 25 April 9, 2019 GHISLAINE MAXWELL Q. Was there ever any other members? A. I don't believe so. Q. Could you tell me who Darren Indyke, Esq. at New York, New York is? Could you tell me who he is? A. He is a lawyer. Q• What is his connection with the LLC? 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. And 13 he helped create it. 14 Q. Was he referred to you by somebody? 15 A. He worked for a friend of mine. 16 Q. Who is that? 17 A. A gentlemen called Mr. Epstein. 18 Q. Sorry? 19 A. A gentleman. 20 Q. Is that Jeffrey Epstein? 21 A. Yes. 22 Q. What was the principal place of business of 23 LLC.? 24 A. Well, didn't do any business. 25 Q. What was the principal place business? Do ( DEITZ Court Reporting... A Lexitas Company 800-678-0166 EFTA00065894 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM) INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 26 April 9, 2019 1 GHISLAINE MAXWELL 2 you maintain books for it? .3 A. I don't have any paperwork regarding that. 4 1 don't have. It would have been with the 5 accountant or whoever was dealing with it then. 6 Q. Were there annual returns that were prepared for that LLC? 8 A. I'm sure there were. 9 Q. Did you sign them? 10 A. I must have. Q. Where are they? :2 A. So long ago I have no idea. I don't have 13 that. 14 Q. Did there come a time period where 15 LLC. purchased the building at 16 ■ New York, New York? 17 A. I am sorry, I don't know the -- I think 18 SO. 19 Q. Who owned your building? 20 A. 21 Q. When was it purchased by them? 22 A. Like I have said, some time in 2000. 23 MR. CUOMO: Before you ask another question 24 I just want to talk to my client for a moment. 25 (A short recess was taken.) DEITZ Court Reporting... A Lexitas Company