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Document 120847-103

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1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms. Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of ? 19 A. I am. 20 Q. Has given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has given a statement 25 to police about Jeffrey Epstein performing --- PAGE BREAK --- Case 1:205-cv-00728-RCL Document 120847-103 Filed 10/28/20 Page 94 of 654 G Maxwell - Confidential 1 2 Q. I'm asking the questions. I know 3 what this case is about. I'm trying to -- I 4 will ask you questions if you don't 5 understand the question I can break it down 6 for you. I'm happy to do that. 7 A. Break it down a lot please. 8 Q. I will do that. 9 The question is, have you ever said 10 to anybody that you recruit other girls -- 11 A. Why don't you stop there. 12 Q. Let me finish my question. 13 Have you ever said to anybody that 14 you recruit girls to take the pressure off 15 you, so you won't have to have sex with 16 Jeffrey, have you said that? 17 That's the question? 18 A. You don't ask me questions like 19 that. First of all, you are trying to trap 20 me, I will not be trapped. You are asking me 21 if I recruit, I told you no. Girls meaning 22 underage, I already said I don't do that with 23 underage people and as to ask me about a 24 specific conversation I had with language, we 25 talking about almost 17 years ago when this MAGNA LEGAL SERVICES DOJ-OGR-00003574 --- PAGE BREAK --- G Maxwell - Confidential took place. I cannot testify to an actual conversation or language that I used with anybody at any time. Q. Have you ever said to anybody that you recruit other females over the age of 18 to take the pressure off you to having to have sex with Jeffrey? A. I totally resent and find it disgusting that you use the word recruit. I already told you I don't know what you are saying about that and your implication is repulsive. Q. Answer my question. A. I just did. Q. Have you ever said to anybody that you recruit females -- A. I don't recruit anybody. Q. That's an answer. So you never said that? A. I'm testifying that I cannot testify to an actual language -- Q. It's a yes or no. A. I will not testify to an actual statement made 17 years ago, so I cannot MAGNA LEGAL SERVICES DOJ-OGR-00003575

Individual Pages

Page 55 - DOJ-OGR-00003571
1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms. Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of ? 19 A. I am. 20 Q. Has given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has given a statement 25 to police about Jeffrey Epstein performing
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Case 1:205-cv-00728-RCL Document 120847-103 Filed 10/28/20 Page 94 of 654 G Maxwell - Confidential 1 2 Q. I'm asking the questions. I know 3 what this case is about. I'm trying to -- I 4 will ask you questions if you don't 5 understand the question I can break it down 6 for you. I'm happy to do that. 7 A. Break it down a lot please. 8 Q. I will do that. 9 The question is, have you ever said 10 to anybody that you recruit other girls -- 11 A. Why don't you stop there. 12 Q. Let me finish my question. 13 Have you ever said to anybody that 14 you recruit girls to take the pressure off 15 you, so you won't have to have sex with 16 Jeffrey, have you said that? 17 That's the question? 18 A. You don't ask me questions like 19 that. First of all, you are trying to trap 20 me, I will not be trapped. You are asking me 21 if I recruit, I told you no. Girls meaning 22 underage, I already said I don't do that with 23 underage people and as to ask me about a 24 specific conversation I had with language, we 25 talking about almost 17 years ago when this MAGNA LEGAL SERVICES DOJ-OGR-00003574
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G Maxwell - Confidential took place. I cannot testify to an actual conversation or language that I used with anybody at any time. Q. Have you ever said to anybody that you recruit other females over the age of 18 to take the pressure off you to having to have sex with Jeffrey? A. I totally resent and find it disgusting that you use the word recruit. I already told you I don't know what you are saying about that and your implication is repulsive. Q. Answer my question. A. I just did. Q. Have you ever said to anybody that you recruit females -- A. I don't recruit anybody. Q. That's an answer. So you never said that? A. I'm testifying that I cannot testify to an actual language -- Q. It's a yes or no. A. I will not testify to an actual statement made 17 years ago, so I cannot MAGNA LEGAL SERVICES DOJ-OGR-00003575