Document 12087-103

G Maxwell - Confidential A. No. Q. Were you aware that Jeffrey was having sexual contact with when she was 13 years old? MR. PAGLIUCA: Object to the form and foundation. A. I would be very shocked and surprised if that were true. Q. Were you in the house when was in the house in a private area with Jeffrey Epstein? MR. PAGLIUCA: Object to the form and foundation. A. Can you repeat the question. Q. Were you ever in the Palm Beach house when Jeffrey Epstein was in the house with ? MR. PAGLIUCA: Object to the form and foundation. A. I've already testified that I have met her and that she was there I don't understand what your question is asking. Q. So you have never seen --- PAGE BREAK --- Case 1:205-cv-00728-PLAP Document#: 12087-103 Filed: 10/28/2019 Page 521 of 654 Page 51 1 G Maxwell - Confidential 2 therapists paid? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. They get paid between $100 and $200. 6 Q. Did it vary based on what sexual 7 acts they performed? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. No. It varied depending how much 11 time, some massage therapists charge more and 12 some charge less. 13 Q. Did the massage therapists that 14 were hired to come to the home perform sexual 15 acts for Jeffrey Epstein? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. What are you asking me? 19 Q. I'm asking if the massage 20 therapists -- 21 A. Are you asking me about underage 22 girls? 23 Q. I'm asking in general, did any of 24 the massage therapists in the home -- 25 A. Are you asking if they were paid MAGNA LEGAL SERVICES DOJ-OGR-00003567 --- PAGE BREAK --- Case 1:12-cv-00748-PLAEP Document 12087-103 Filed 09/29/20 Page 531 of 634 Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by 11 sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of those things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking 21 for to your knowledge any consensual sex 22 act that may or may not have involved 23 you, I'm instructing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex Magna Legal Services DOJ-OGR-00003568 --- PAGE BREAK --- Case 1:205-cv-00728-PLF Document 12087-103 Filed 10/28/20 Page 54 of 654 Page 53 1 G Maxwell - Confidential 2 acts. I'm asking whether any of the massage therapists performed sexual acts for Mr. 3 Epstein, as I have just described? 4 A. I have never seen anybody have 5 sexual intercourse with with Jeffrey, ever. 6 Q. I'm not asking about sexual 7 intercourse. I'm asking about any sexual 8 act, touching of the breast -- did you ever 9 see -- can you read back the question? 10 (Record read.) 11 12 A. I'm not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts, that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for 23 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. MAGNA LEGAL SERVICES DOJ-OGR-00003569 --- PAGE BREAK --- G Maxwell - Confidential not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that question? A. You just heard my counsel. Q. Have you ever said to anybody that recruiting other girls to perform sexual massages for Jeffrey Epstein takes the pressure off you? MR. PAGLIUCA: Object to the form and foundation. A. Repeat the question and break it out. Q. Have you ever said to anybody that you recruit girls -- A. Stop right there. I never recruited girls, let's stop there. Now breakdown the question. Q. Have you ever said to anybody -- A. By girls, we are talking about underage people -- you said girls, are you talking about underage -- we are not talking about consensual acts -- this is a defamation suit. MAGNA LEGAL SERVICES DOJ-OGR-00003573