Document 1204-10

Case 1:20-cv-00233-PAE Document 1204-10 Filed 10/22/01 Page 881 of 455 Page 137 G Maxwell - Confidential 1 the flights? 2 A. I can't recollect having a meal 3 with them, but just so we are clear, the 4 allegations that had a meal on 5 Jeffrey's island is 100 percent false. 6 Q. But he may have had a meal on 7 Jeffrey's plane? 8 A. I'm sure he had a meal on Jeffrey's 9 plane. 10 Q. You do know how many times he flew 11 on Jeffrey's plane? 12 A. I don't. 13 Q. Do you know who is? 14 A. I do. 15 Q. How do you know him? 16 A. He used to work or still works for 17 18 Q. Did you ever have a relationship 19 with him? 20 A. We are talking about adult 21 consensual relationships, it's off the 22 record. 23 Q. I'm not asking what you did with 24 him, I'm asking if you ever had a 25 MAGNA LEGAL SERVICES DOJ-OGR-00003576 --- PAGE BREAK --- Case 1:20-cv-00233-PAE Document 1204-10 Filed 10/12/21 Page 183 of 155 1 G Maxwell - Confidential 2 sexually abused any minor children? 3 A. Again, I only know 1000 percent 4 that Virginia is a liar. I can only talk to 5 Virginia, her lies and your inappropriate, 6 unethical, really unattractive, terrible use 7 of her and the way that you have abused the 8 system, used the press for purposes that are 9 unethical, inappropriate and appalling. 10 Q. Do you believe that Jeffrey Epstein 11 used messages to lure minors to have sex with 12 him? 13 A. Again, that is Virginia's 14 testimony, which is a lie. 15 Q. But do you believe that? 16 A. Again, I refer back to Virginia. 17 Q. I'm asking whether you believe it 18 or not? 19 A. I can only go with what I know and 20 I know Virginia is a liar and therefore 21 that's a lie. 22 Q. So you don't believe that? 23 A. I said, I only know that Virginia 24 is lying. 25 Q. Are you aware that Jeffrey Epstein MAGNA LEGAL SERVICES DOJ-OGR-00003581 --- PAGE BREAK --- Case 1:20-cv-00233-JAP Document 1204-10 Filed 10/22/01 Page 837 of 455 Page 184 G Maxwell - Confidential 1 2 is a registered sex offender? 3 A. I am. 4 Q. Are you aware that Jeffrey Epstein 5 paid considerable amounts of money to settle 6 lawsuits with the minor children that he had 7 sexual contact with? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have no knowledge of those 11 issues. 12 Q. Why did you continue to maintain 13 contact with Jeffrey Epstein after he pled 14 guilty? 15 A. I'm a very loyal person and Jeffrey 16 was very good to me when my father passed 17 away and I believe that you need to be a good 18 friend in people's hour of need and I felt 19 that it was a very thoughtful, nice thing for 20 me to do to help in very limited fashion 21 which was helping if he had any issue with 22 his homes, in terms of the staffing issues. 23 It was very, very minor but I felt it was 24 thoughtful in somebody's hour of need. 25 Q. Did he continue to pay you during MAGNA LEGAL SERVICES DOJ-OGR-00003582 --- PAGE BREAK --- Case 1:20-cv-00233-JAP Document 1204-10 Filed 10/22/20101 Page 246 of 435 1 G Maxwell - Confidential 2 lots of different types of people. In terms 3 of whatever -- very small part of my job, 4 Jeffrey enjoyed getting massages. I think 5 that is something we can all agree in this 6 room and within the context of that, very 7 infrequently I would go to spas and myself 8 happily receive a professional nonsexual 9 massage from a man and/or from a woman and if 10 that massage was something that I thought was 11 something that was good, I would ask if that 12 man or woman would come back and does home 13 visits. If that person said that they did, 14 they would sometimes come, from time to time, 15 not always, come back to the house to perform 16 a nonsexual professional male or female 17 massage. 18 Q. Were any of the exercise 19 instructors you hired under the age of 18? 20 A. Again, I don't hire, we've already 21 established that I don't hire people. I 22 interview people to see if they are competent 23 in the job that they do and/or whether they 24 are someone who seemed that they can do home 25 visits. MAGNA LEGAL SERVICES DOJ-OGR-00003587 --- PAGE BREAK --- Case 1:20-cv-00233-JPAE Document 1204-10 Filed 10/22/19 Page 483 of 455 Page 247 1 G Maxwell - Confidential 2 At the point where I think that 3 there is somebody that has, can be either 4 whatever the job may be, pool, gardener, chef 5 and/or exercise instructor and I think they 6 could be good at whatever it is at whatever 7 skill that they had and they did a home visit 8 which would obviously be mandatory and Mr. 9 Epstein would meet with them and decide if he 10 wanted to have whatever skill it was that he 11 would do it and then he would then either 12 have them come back or hire them. 13 Q. Were there any exercise instructors 14 that worked at the home that were under the 15 age of 18? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Again, I keep coming back to this, 19 that the people that I employed or -- not the 20 right word, the people I would meet to come 21 and work at the house, under any guise 22 whatsoever, again, from any of the many 23 positions that I filled, were all over -- 24 were adults. 25 Q. When you say adults, over the age --- PAGE BREAK --- Case 1:20-cv-00233-JPAE Document 1204-10 Filed 10/22/21 Page 251 of 455 G Maxwell - Confidential Page 251 1 Q. Were there any 16 year year old masseuse that you are aware of? 2 A. I am not aware. 3 Q. Any 15? 4 A. I just want to be clear. The only person that I am aware of who claims to have been a -- we have to -- we established Virginia now is 17, given she has changed her age so many times. The only person that I am aware of that was a masseuse at the time when I was present in the house was Virginia. 5 Q. Is it an obvious lie that Jeffrey Epstein had a sexual preference for underage minors? 6 MR. PAGLIUCA: Objection to the form and foundation. 7 A. Can you ask the question again? 8 Q. It is it an obvious lie that Jeffrey Epstein had a sexual preference for underage minors? 9 MR. PAGLIUCA: Objection to the form and foundation. 10 A. Can you ask the question again? 11 Q. Is it an obvious lie that Jeffrey MAGNA LEGAL SERVICES DOJ-OGR-00003592 --- PAGE BREAK --- Case 1:20-cv-00233-IPJ Document 1204-10 Filed 10/22/19 Page 253 of 455 Page 252 1 G Maxwell - Confidential 2 Epstein had a sexual preference for underage 3 minors? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I cannot testify to what 7 Jeffrey's -- 8 Q. You don't know his preference? 9 A. You handed me a stack of papers 10 from the police reports and that's what I've 11 read but I have no knowledge, direct 12 knowledge, of what you are referencing. 13 Q. So you don't know, you don't know 14 in your own mind that Jeffrey Epstein had a 15 sexual preference for underage minors, is 16 that correct? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 Q. Is that correct? 20 A. Please ask the question again. 21 Q. You don't know in your own mind 22 that Jeffrey Epstein had a sexual preference 23 for underage minors? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. You have to pause, MAGNA LEGAL SERVICES DOJ-OGR-00003593 --- PAGE BREAK --- Case 1:20-cv-00233-PAE Document 1204-10 Filed 10/22/01 Page 254 of 455 1 G Maxwell - Confidential 2 to recruit underage girls for sexual 3 massages? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. If you know. 7 A. I don't know what you are talking 8 about. 9 Q. Is it an obvious lie that Virginia 10 Giuffre was a minor the first time she was 11 taken to Jeffrey Epstein's house? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. So we've already established that 15 Virginia was 17 and we have established that 16 her mother brought her to the house and that 17 she came as a masseuse, age 17, which is 18 legal in Florida. 19 Q. Would Jeffrey Epstein's assistants 20 arrange times for underage girls to come to 21 the house for sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. What are you talking about? 25 Q. Sure. Would Jeffrey Epstein's --- PAGE BREAK --- Case 1:20-cv-00233-PAE Document 1204-10 Filed 10/22/01 Page 384 of 455 Page 384 1 G Maxwell - Confidential 2 Jeffrey that was under the age of 18? 3 MR. PAGLIUCA: Objection to form 4 and foundation. Mischaracterizes her 5 testimony. 6 A. I didn't hire people. 7 Q. I said met. 8 A. I interviewed people for jobs for 9 professional things and I am not aware of 10 anyone aside from now Virginia who clearly 11 was a masseuse aged 17 but that's, at least 12 that's how far we know that I can think of 13 that fulfilled any professional capacity for 14 Jeffrey. 15 Q. List all the people under the age 16 of 18 that you interacted with at any of 17 Jeffrey's properties? 18 A. I'm not aware of anybody that I 19 interacted with, other than obviously 20 Virginia who was 17 at this point? 21 (Maxwell Exhibit 21, email, marked 22 for identification.) 23 Q. I'm showing you what's been marked 24 as Maxwell 21, it's an email dated January 25 21, 2015 from Jeffrey to you. Is that, you MAGNA LEGAL SERVICES DOJ-OGR-00003598 --- PAGE BREAK --- Case 1:20-cv-00233-JB Document 1204-10 Filed 10/22/19 Page 144 of 155 Page 413 G Maxwell - Confidential MS. McCAWLEY: I will state for the record there were questions today that remain unanswered because the witness has been instructed not to answer those questions and we will be raising our objections with the court to be able to have those questions answered in the near future. MR. PAGLIUCA: So we are clear, we are designating this entire deposition as confidential under the protective order. That would cover the paralegal whose been present as well as the court reporter and the videographer and all the lawyers in the room. THE VIDEOGRAPHER: This concludes today's proceedings. We are off the record at 6:43 p.m. (Time noted: 6:43 p.m.) MAGNA LEGAL SERVICES DOJ-OGR-00003599