Document 1:20-cv-00233

Case 1:20-cv-00233-IPAP Document 1207-10 Filed 10/22/01 Page 138 of 155 Page 138 1 G Maxwell - Confidential 2 relationship with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic. I was friends with but you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 , do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and MAGNA LEGAL SERVICES DOJ-OGR-00003577 --- PAGE BREAK --- Case 1:20-cv-00233-IPAE Document 1207-10 Filed 10/22/01 Page 829 of 835 Page 186 G Maxwell - Confidential 1 2 Q. Did you have an attorney to consult with during the criminal investigation of 3 4 Jeffrey Epstein? 5 A. I don't believe I did. 6 Q. When did you learn that a search warrant was executed for the Palm Beach 7 8 house? 9 A. I don't recall exactly. 10 Q. Were you present at the house in advance of the search warrant being executed? 11 12 MR. PAGLIUCA: Object to the form 13 of the question. 14 A. I don't remember when the search warrant was executed and I don't remember the 15 16 year that the search warrant was executed and whenever that was, I already testified, I was 17 18 very, very infrequently at the house. So highly unlikely but I was there a couple of 19 20 days, I just don't know which days it was in relation to the police situation. 21 22 Q. Did you have a computer at the Palm Beach home that was a computer that you would 23 24 use? 25 A. No. MAGNA LEGAL SERVICES DOJ-OGR-00003584 --- PAGE BREAK --- Case 1:20-cv-00233-IPAE Document 1207-10 Filed 10/22/21 Page 244 of 455 G Maxwell - Confidential 1 I took of people would only have been mainstream type magazine type photos and any photos I took could have been very happily and expected to be displayed on your parents' mantel piece or grandparents' mantel piece. Q. Is it a lie that you approached females to bring them to Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. Please ask the question, again. Q. Sure. Is it a lie that you approached females to bring them to Jeffrey Epstein? A. I don't know what you are asking me. Q. I'm asking you, if it's a lie that you approached females to bring them to Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. You are not asking me a good question, sorry. Q. You don't get to choose the questions. MAGNA LEGAL SERVICES DOJ-OGR-00003585 --- PAGE BREAK --- Case 1:20-cv-00233-JPAE Document 1207-10 Filed 10/22/21 Page 248 of 435 Page 245 G Maxwell - Confidential 1 I would like to answer your 2 A. questions but you are not asking me a 3 question that I can answer. 4 Q. What about that is causing you 5 pause where you can't answer the question? 6 A. You are trying to trap me and 7 that's not fair, so I already testified that 8 I hire people across the board, so I would 9 hire architects, decorators, pool people, 10 exercise instructors, gardeners, cooks, 11 chefs, cleaning people. So I, in the course 12 of a very long time when I would hire people 13 I hired people to work for Jeffrey. So I'm 14 happy to testify to hiring people for every 15 possible conceivable proper job that you 16 could conceive of within the context of 17 Jeffrey's life and homes. 18 Q. Is it a lie that you approached 19 females to bring them to Jeffrey Epstein for 20 the purpose of performing massages? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Again, I have already testified 24 that part of the job that I had was to hire 25 MAGNA LEGAL SERVICES DOJ-OGR-00003586 --- PAGE BREAK --- G Maxwell - Confidential 1 of 18? A. I think we can establish what adult would be. Q. You never interviewed or I know you don't want to use the word hired, whatever your role was, you brought in an exercise instructor that was under the age of 18 to work at the house? MR. PAGLIUCA: Object to the form and foundation. A. I have already testified that what I was responsible for was to find people who had competencies in whatever area I was looking for. The competencies I was looking for were professional and adult. Q. So there was no exercise instructor that worked at the Palm Beach house or the New York house or the New Mexico house or the USVI under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. I can only testify to when I was at the house. Q. Yes. --- PAGE BREAK --- Case 1:20-cv-00233-IPAP Document 1207-10 Filed 10/22/21 Page 250 of 455 Page 250 1 G Maxwell - Confidential 2 agree to that? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. Are they under the age of 18? 6 A. We already established that you can 7 be a masseuse in Florida at age 17. That 8 does not make it inappropriate. 9 A. I'm not saying appropriate or 10 inappropriate. I'm just asking if there were 11 any exercise instructors that were under the 12 age of 18. 13 A. I am not aware if anybody was but I 14 don't want to full out and say you on she 15 said, we already established you can be a 17 16 year old masseuse and have it not be 17 something that is not appropriate. So when 18 you say that and then you go, well, you come 19 back and say something, now we can establish 20 that Virginia was 17 but you can be a 17 year 21 old legal masseuse, but I am not aware to 22 your point. 23 Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any. MAGNA LEGAL SERVICES DOJ-OGR-00003591