Document 533-2

Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 1 of 19 Exhibit B DOJ-OGR-00008282 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 3 of 19 Page 2 1 2 APPEARANCES: 3 4 BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdale, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE 7 EMMA ROSEN, PARALEGAL 8 9 FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, P.L. Attorneys for Plaintiff 425 N. Andrews Avenue 10 Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 PAUL G. CASSELL, ESQUIRE 13 Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenue 18 Denver, Colorado 80203 19 BY: JEFFREY S. PAGLIUCA, ESQUIRE 20 LAURA A. MENNINGER, ESQUIRE 21 Also Present: 22 James Christe, videographer 23 24 25 MAGNA LEGAL SERVICES DOJ-OGR-00008284 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 4 of 19 Page 312 1 G Maxwell - Confidential 2 Q. Would you visit more than one 3 university to try to find individuals to work 4 for Jeffrey Epstein? 5 A. As I recollect, I think that's, in 6 fact, the only university I went to. 7 Q. Did you go there more than once? 8 A. I think I went twice. 9 Q. Who else did you find from that 10 university, was there anybody other than 11 12 A. I don't recollect, I'm sorry. 13 Q. We are going to mark this as 14 Maxwell 13? 15 (Maxwell Exhibit 13, documents, 16 marked for identification.) 17 Q. Can you take a look at the document 18 I put in front of you, please. 19 Are you familiar with this 20 document? 21 A. I'm familiar with this actual 22 document. 23 Q. How was this document created? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA LEGAL SERVICES DOJ-OGR-00008285 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 5 of 19 Page 313 1 G Maxwell - Confidential 2 A. I don't know how this document was 3 created. 4 Q. You were involved in the creation 5 of this document? 6 A. I think you can see from the date 7 that it's 2004, 2005, so no. 8 Q. You weren't involved in the 9 creation of this document. 10 Did you -- we talked earlier about 11 Mr. Epstein's house, I'm talking about the 12 Palm Beach house where you said there was a 13 computer on the desk, that employees had 14 access to -- people who worked for Jeffrey 15 Epstein may have had access to? 16 A. I think anybody could have had 17 access to that. 18 Q. Was that computer used, if you know 19 to keep a log of addresses and phone contact 20 information for Jeffrey Epstein? 21 A. Are we talking about when this 22 document was created. 23 Q. In general, was there, on that 24 computer during the time that you were 25 present with Jeffrey Epstein, was there a MAGNA LEGAL SERVICES DOJ-OGR-00008286 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 6 of 19 Page 314 1 G Maxwell - Confidential 2 mechanism by which you kept electronic 3 information of names and addresses of 4 individuals that he knew? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I can't testify to what was on that 8 computer or not after I was gone. 9 Q. Not when you were gone, when you 10 were there. If Jeffrey wanted to call, for 11 example, say , would someone be 12 able to go to that computer to pull up the 13 address information and phone contact 14 information for that individual? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I couldn't possibly say. 18 Q. Did you ever have to keep track of 19 address or phone contact information for 20 Jeffrey Epstein? 21 A. That was not my job. 22 Q. Did you ever do it? 23 A. I am not responsible for keeping 24 his numbers so that wasn't my job at all. 25 Q. But did you ever do it? I know MAGNA LEGAL SERVICES DOJ-OGR-00008287 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 7 of 19 Page 315 1 G Maxwell - Confidential 2 it's not your job but did you ever do it, did 3 you ever keep phone contact information for 4 him? 5 A. During the course of the time we 6 were together, if he gave me a telephone 7 number, I would give it to an assistant to 8 put in the computer, I could do that. 9 Q. Would he ask you for contact 10 information for different individuals, if he 11 wanted to contact someone? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. In the course of the long period of 15 time when I was there, it certainly would be 16 possible for him to ask me for a telephone 17 number and if I had the -- I wouldn't always 18 have it -- I'm sure it happened. 19 Q. Was there a hardcopy book in 20 addition to the computer, a hardcopy book 21 that you could look for numbers that were 22 relevant to Jeffrey Epstein's life and 23 something on the computer or was it just an 24 electronic version? 25 MR. PAGLIUCA: Objection to the MAGNA LEGAL SERVICES DOJ-OGR-00008288 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 8 of 19 Page 316 1 G Maxwell - Confidential 2 form and foundation. 3 Q. Was there a hard copy book as well 4 as something on the computer or was there 5 only electronic information on the phone 6 numbers? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can only testify to what I know 10 obviously, and I believe that this is a copy 11 of a stolen document. I would love to know 12 how you guys got it. 13 Q. I'm asking during the time you 14 worked for Jeffrey Epstein, was there a 15 hardcopy document of any kind that kept phone 16 numbers for Jeffrey Epstein, if he needed to 17 contact someone? 18 A. The stolen document I have in front 19 of me that you have is what you are referring 20 to. 21 Q. So there was, during your time when 22 you were there, there was no other, you 23 mentioned there was information on a 24 computer. Was there any hardcopy document 25 that you could refer to to find someone's MAGNA LEGAL SERVICES DOJ-OGR-00008289 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 9 of 19 Page 317 1 G Maxwell - Confidential 2 number? 3 A. You have the stolen document in 4 front of you. 5 Q. You had access to this when you 6 worked for Jeffrey Epstein? 7 A. This is, I believe, the book that 8 was stolen, that was the hardcopy of whatever 9 was there. 10 Q. So when you were working for 11 Jeffrey Epstein, you were able to access this 12 book? 13 A. This book -- if this is what this 14 is, I believe it was, this is the stolen 15 document from his house. 16 Q. And you were able to access it when 17 you worked for him? 18 A. It was a document that was printed 19 that you could, if you needed to, look for a 20 number. 21 Q. Do you know how this book was 22 created? 23 A. No. 24 Q. When you referred to it a moment 25 ago, to a stolen document, when MAGNA LEGAL SERVICES DOJ-OGR-00008290 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 10 of 19 Page 318 1 G Maxwell - Confidential 2 turned this document over to the 3 FBI, are you aware he described it as a 4 document that came from your computer? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea what he said or 8 didn't say, so if you want me to reference 9 something he said, you need to show it to me. 10 Q. Did you keep this document, an 11 electronic copy of it, on your personal 12 computer? 13 A. I don't recollect. 14 Q. If you had to update something, for 15 example, if there was a new number, a new 16 individual that Jeffrey had hired that you 17 were going to track, would you input that 18 information into this document on your 19 computer? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I've already testified that I'm not 23 responsible for updating and keeping these 24 records. 25 Q. Did you have this document on your --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 11 of 19 Page 319 1 G Maxwell - Confidential 2 computer, your personal computer? 3 A. I told you, I don't recollect 4 having this document on my computer. 5 Q. Do you know what computers this 6 document was on, if more than one? 7 A. I'm sorry, this is a long time ago 8 and I don't recall exactly how this was all 9 managed. 10 Q. If you didn't create this document, 11 do you know who did? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I don't. 15 Q. I'm going to direct your attention 16 to part of this document. It's towards the 17 back, it's going to be page 91 and it has 18 bates label Giuffre 001663. I'm going to 19 direct your attention to the section that 20 says, Massage Florida. 21 Did you input any of the names or 22 numbers under that section? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. So this document is produced in MAGNA LEGAL SERVICES DOJ-OGR-00008292 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 12 of 19 Page 320 1 G Maxwell - Confidential 2 2004, 2005, so, no. 3 Q. But I'm sorry, correct me if I'm 4 misunderstanding your testimony, I thought 5 you said when you were working with Jeffrey, 6 that this document existed and it was 7 something you utilized? 8 A. I can't possibly tell you what 9 numbers were added or not added subsequent to 10 my departure. 11 Q. So you can't recall if you added 12 any of these numbers? 13 MR. PAGLIUCA: Objection to the 14 form and foundation, mischaracterizes 15 the witness' testimony. 16 Q. Are there any numbers on here or 17 names that you recognize that you would have 18 entered into this section? 19 A. I already testified that I'm not 20 responsible for inputting numbers and names 21 into this so I would not be able to tell you. 22 Q. Are there any names or numbers 23 under this section, Massage Florida, that you 24 would have provided to an assistant to input 25 into this document? MAGNA LEGAL SERVICES DOJ-OGR-00008293 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 13 of 19 Page 321 1 G Maxwell - Confidential 2 A. I can't possibly say. 3 Q. Do you see under Massage Florida, 4 about halfway down the first column, do you 5 see a number that says cell? 6 MR. PAGLIUCA: What page? 7 Q. It's 91, Bates number 001663. 8 About halfway down, it says in the first 9 column, it says cell. 10 Do you see that? 11 A. I do. 12 Q. Would you have provided after, I 13 know you didn't hire her, Jeffrey hired her 14 but after you brought her to Jeffrey, would 15 you have given her cell phone number to an 16 assistant to input into this document? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I didn't bring her to Jeffrey, the 20 way you characterize and I would have no 21 knowledge of how this number ended up in this 22 book. 23 Q. I believe you, and I will try to 24 use your words so we are clear, you met 25 is that correct? MAGNA LEGAL SERVICES DOJ-OGR-00008294 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 14 of 19 Page 322 1 G Maxwell - Confidential 2 A. Yes. 3 Q. And then she began working for 4 Jeffrey? 5 A. Yes. 6 Q. Would you have provided whomever 7 was in charge of keeping this updated with 8 [redacted] cell number so you would be able to contact her if needed? 9 10 MR. PAGLIUCA: Objection to the form and foundation. 11 12 A. I don't know. It could have been a number of different ways, it it could have 13 been Jeffrey who gave it to somebody. 14 15 Q. You just don't remember doing that? 16 A. I do not. 17 Q. Now, as you look -- I want you to take a look at the Florida massage list, it's three columns there. 18 19 20 Do you, as you look at those names on the various columns, do you know the ages 21 of any of the girls in this list? 22 23 A. I don't know. One, I don't know who all the people are on this list and I certainly don't know the ages. 24 25 MAGNA LEGAL SERVICES DOJ-OGR-00008295 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 15 of 19 Page 323 1 G Maxwell - Confidential 2 Q. Do you know what their 3 qualifications are? 4 A. I don't know who the people are in 5 general so of course I don't know what their 6 qualifications are. 7 Q. Do you know why Jeffrey has so many 8 masseuses listed in Florida in his book here? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Again, this book was created post 12 my departure, so I couldn't explain why all 13 these people were here. 14 Q. When you were there, you said this 15 book existed? 16 A. Yes. 17 Q. So when you were there, were there 18 a number of masseuses listed under the 19 Florida massage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation and 22 mischaracterization of the witness' 23 testimony. 24 Q. I'm asking you a question. 25 When you were there, were there a MAGNA LEGAL SERVICES DOJ-OGR-00008296 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 16 of 19 Page 324 1 G Maxwell - Confidential 2 number of masseuses listed under the Florida 3 massage section? 4 A. When I was there, I would have, of 5 course there would have been some masseuses 6 listed but I could not tell you who or how 7 many and this -- I could not possibly because 8 I wouldn't remember. 9 Q. Do you know why Jeffrey would have 10 had so many names listed under his massage 11 Florida? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I can't testify to why Jeffrey has 15 so many. 16 Q. Did he use a different masseuse 17 every day? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. You can answer. 21 A. When I was there he had a massage 22 roughly every day, one masseuse, and mostly 23 he would have them at random times, so it 24 would be difficult if you just only had one 25 person, man, woman, for an adult massage, to MAGNA LEGAL SERVICES DOJ-OGR-00008297 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 17 of 19 Page 325 1 G Maxwell - Confidential 2 come and be available for whatever time it 3 was. So he would have more than one person 4 that he could call for a massage because at 5 any given time the one that he called first 6 may not have been available. 7 Q. So would it typically be a 8 different person each day that would give him 9 a massage? 10 11 12 A. It would be, when I was there, 13 based on availability. 14 Q. Would it surprise you to learn that 15 the Federal Government found that some of the 16 girls on this list under massage Florida were 17 under the age of 18? 18 19 20 A. I can't testify to what the 21 government found or did not find because I 22 would have no knowledge of it. 23 Q. I'm asking if you would be 24 surprised by that? 25 MR. PAGLIUCA: Objection to the form and foundation. MR. PAGLIUCA: Form and foundation. MAGNA LEGAL SERVICES DOJ-OGR-00008298 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 18 of 19 Page 326 1 G Maxwell - Confidential 2 A. I have knowledge of it. I can't speculate. 3 Q. On the second column, towards the bottom, there is the name, it's one up from 4 the bottom, there is the name , do you know ? 5 A. I do. 6 Q. Who is she? 7 A. She was a friend of Jeffrey's. 8 Q. Is she a masseuse? 9 A. She, I don't think she was a masseuse, no. 10 Q. Why would be she listed under Florida massages? 11 A. An input error. 12 Q. Is this list any individual that would have sex with Jeffrey? 13 MR. PAGLIUCA: Objection to the form and foundation. 14 A. I wouldn't have any knowledge of that. 15 Q. Do you know if Jeffrey had sex with ? 16 MR. PAGLIUCA: Object to the form 17 MAGNA LEGAL SERVICES DOJ-OGR-00008299 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 19 of 19 Page 327 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, I wouldn't have any 4 knowledge of that. 5 MS. McCAWLEY: We are going to take 6 a quick break. 7 THE VIDEOGRAPHER: It's now 4:39 8 and we are off the record. 9 (Recess.) 10 THE VIDEOGRAPHER: It's now 4:54 11 and we are as back on the record 12 starting disk number 8. 13 Q. Ms. Maxwell, we were talking 14 earlier about the journal and I believe you 15 said in 2004, 2005, you were no longer 16 working and responsible for that journal, is 17 that correct? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. What are we referring to, this 21 document right here? 22 Q. Yes. 23 A. I don't know who is the author of 24 this or I can't tell you what is in here 25 versus what would have been here when I was MAGNA LEGAL SERVICES DOJ-OGR-00008300