Case Document Filed Page of Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE Plaintiff Case No against GHISLAINE MAXWELL Defendants CONFIDENTIAL Videotaped deposition of GHISLAINE MAXWELL taken pursuant to subpoena was held at the law offices of BOIES SCHILLER FLEXNER Lexington Avenue New York New York commencing April a.m on the above date before Leslie Fagin a Court Reporter and Notary Public in the State of New York MAGNA LEGAL SERVICES Avenue of the Americas New York New York Case Document Filed Page of MAGNA9 LEGAL SERVICES Page APPEARANCES BOIES SCHILLER FLEXNER LLP Attorneys for Plaintiff East Las Olas Boulevard Fort Lauderdatle Florida BY SIGRID McCAWLEY ESQUIRE MEREDITH SCHULTZ ESQUIRE EMMA ROSEN PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L Attorneys for Plaintiff Andrews Avenue Fort Lauderdale Florida BY BRAD EDWARDS ESQUIRE PAUL CASSELL ESQUIRE Attorneys for Plaintiff South University Street Salt Lake City Utah HADDON MORGAN FOREMAN Attorneys for Defendant East 10th Avenu Denver Colorado BY JEFFREY PAGLIUCA ESQUIRE LAURA A MENNINGER ESQUIRE Also Present James Christe videographer Case Document Filed Page of MAGNA9 LEGAL SERVICES Page THE VIDEOGRAPHER We are now on the record and recording This begins disk No in the deposition of Ghislaine Maxwell in the matter of Virginia Giuffre versus Ghislaine Maxwell in the U.S District Court for the Southern District of New York Today is April the time is a.m This deposition is being taken at Lexington Avenue in New York at the request of Sigrid McCawley of Boies Schiller Flexner The videographer is James Christe and the court reporter is Leslie Fagin Will counsel state their appearance and whom they represent and then court reporter swear in Ms Maxwell MS McCAWLEY My name is Sigrid McCawley with my colleague Meredith Schultz We are with Boies Schiller Flexner We represent Ms Giuffre MR EDWARDS Brad Edwards I also represent Ms Giuffre MR CASSELL Paul Cassell I also Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential represent Ms Giuffre MR PAGLIUCA Jeff Pagliuca and Laura Menninger on behalf of Ms Maxwell I A I A called as a witness having been duly sworn by a Notary Public was examined and testified as follows EXAMINATION BY MS McCAWLEY Good morning Im going to explain some of the rules that will happen with respect to depositions Have you ever been deposed before A I have not What is going to happen here we have a court reporter and a videographer What they do is take down the words that we say so when I ask you a question they will record what you say in response to that So we have to be mindful that in order for them to do their job we cant talk over each other Another issue you have to be weary Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential of is that in a response you cant give a nonverbal response in other words nodding a yes or no they need to hear verbal response so they can record it on their transcript So thats important for you to remember as we go through the day If you forget I will be sure to remind you Is there anything that would prevent you from giving truthful testimony today A There is not You are not on any medications or anything that would inhibit your ability to remember or give truthful testimony A I am not MR PAGLIUCA Could you identify the assistant in the room MS McCAWLEY This is Emma Rosen from our New York office She is a paralegal Ms Maxwell can you please state your address for the record A Currently What is your date of birth Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A When did you first recruit a female to work for Mr Epstein MR PAGLIUCA I object to the form and foundation of the question I believe this is confidential information I ask anyone who is not admitted in this case be excused from the room please MS McCAWLEY So the response to that question would MR PAGLIUCA The subject matter of this question is confidential and Im designating it as confidential MS McCAWLEY I just want to make that clear for the record MR EDWARDS So we dont delay the deposition I will step out of the room but I think its important to lay the record that MR PAGLIUCA Im sorry you are not admitted in this proceeding so you are not entitled to make any record If Ms McCawley wants to make a record she Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential can MR EDWARDS I can make a record right now MR PAGLIUCA Maybe we should get the judge on the phone and talk about it MR EDWARDS The record will be short This is the precise reason why Ms Giuffre wants me in this case and Im unable to effectively represent her at this time because I am unable to have access to the confidential information which includes apparently the entire deposition of Ms Maxwell But for the sake of not further delaying this I will be outside the room MS McCAWLEY Thank you A I would like to just wait for him to leave Thats fine A I would just like to clarify the address Im in the process of selling the house so while while I still receive mail there its not my actual physical address Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Its in the process of being sold It still requires some final paperwork to be done so just for the purposes of clarity Do you have a new address where you will be living A I do not For the purpose of the record if there is something I ask you that you later remember something else or need to correct your testimony in some way you can do that just let me know what it is and we will go back to that question and can you clarify A Of course I just wanted to be clear there is still some paperwork pending for final release but its in the process of sale But I dont have another address currently so whilst that should still be of record that the mail could be forwarded there so for purposes of clarity I wanted to be clear I appreciate that So Ms Maxwell when did you first recruit a female to work for Mr Epstein MR PAGLIUCA Again I object to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation of the question You can answer the question A First of all can you please clarify the question I dont understand what you mean by female I dont understand what you mean by recruit Please be more clear and specific about what you are suggesting Are you a female is that the sex that you are A I am a female Thats what Im referring to a female and Im asking you when you first the very first time you recruited a female to work for Mr Epstein A Again I dont understand what female I am a year old women Im not making it age any age of a female that you recruited to work for Mr Epstein A Again I was somebody who hired a number of people to work for Mr Epstein and hiring is one of my functions And when is the first time you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential hired someone to work for Mr Epstein a female A As best as I can recollect a woman the age probably of about or was in sometime in How long did you work for Mr Epstein A I started working for him at some point in and the nature of my work relationship with him changed over time so from around the work lessened considerably When did you MR PAGLIUCA Can I interject for a moment If we are talking about background MS McCAWLEY Im in the middle of a question Let me finish it and then can you interject When you say to that the work lessened when did you complete working for Mr Epstein when was the last time you were employed by him the last date A I believe I still was doing Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential helping him in a very nominal way maybe an hour or two a year at sometime and MR PAGLIUCA So if you are going to be talking about general background I dont need to designate that as confidential So if you want to have them come back in thats fine I assumed by your first question you were going into more sensitive areas I will leave it up to you but if this is general background it will not be designated as confidential MS McCAWLEY I appreciate that I will jump back into my other questions MR PAGLIUCA So we will keep it as confidential When you were first employed by him in what were you hired to do A First I was consulting and what I did was I helped with decorating houses and in hiring staff to help run those houses Did your duties change over the course of to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation A My job entailed running the homes that he had but much more importantly most of the houses had construction and so whilst in there was no construction project there was construction projects that began after that time and I was in charge not only of hiring architects I was also in charge of all the filings or overseeing that like a general contractor would I also helped with hiring the architects hiring the builders reviewing the contracts for the builders coordinating the building projects coordinating how the projects would layout the timing of the projects and all the various materials that they would require to run a very substantial building project Thats the nature of the job I was dealing with How old was the youngest female you ever hired to work for Jeffrey MR PAGLIUCA Object to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential You can answer A I have not any idea exactly of the youngest adult employee that I hired for Jeffrey When you say adult employee did you ever hire someone that was under the age of A Never Did you ever bring someone who was under invite someone under the age of to Jeffreys home any of his homes MR PAGLIUCA Object to the form foundation A Can you repeat the question Did you ever invite anybody who was under the age of to Jeffreys homes MR PAGLIUCA Same objections A I have a number of friends that have children and friends of mine that have kids and in the invitation of my friends and their kids Im sure I may have invited some of my friends kids to come Anybody that is not a friend of yours Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Any female under the age of did you invite them to come to Jeffreys home MR PAGLIUCA Object to the form and foundation A Again as I said I am not aware of inviting anybody other than friends of mine who have children to the house Did you invite Virginia Giuffre to come to Jeffrey Epsteins home when she was under the age of MR PAGLIUCA Object to the form and foundation A Virginia Roberts held herself out as a masseuse and invited herself to come and give a massage My question is did you invite Virginia Roberts when she was under the age of to come to Jeffrey Epsteins home MR PAGLIUCA Object to the form and foundation A Again Virginia Roberts was a masseuse Im asking not asking if she was a masseuse Im asking if you invited her to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential come to Jeffrey Epsteins home A Again there would be no course to have a conversation with Virginia unless she held herself out to be a masseuse Im not asking that question Im asking if you invited her to come to Jeffrey Epsteins home when she was under the age of A Again I repeat she was a masseuse and in the form and as my job I was to have people who he wanted for various things including massage She came as a masseuse So you invited her to his home to come to give a massage is that correct MR PAGLIUCA Object to the form and foundation Misstates the witness testimony A Again I did not invite Virginia Roberts She came as a masseuse She who invited her to come as a masseuse she just showed up at the front door MR PAGLIUCA Object to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Ms Roberts held herself out Im not asking how she held herself out Im asking how she arrived at the home Did you meet her and invite her to come to the home or how did she arrive there MR PAGLIUCA Object to the form and foundation A Ms Roberts held her to be a masseuse and her mother drove her to the house When did you first meet Virginia Roberts A I dont have a recollection of the first meeting Do you recall meeting her at Mar-a-Lago A Like I said I dont have a recollection of meeting Ms Roberts So you recall Ms Roberts being brought to the home by her mother is that your testimony A That is my testimony And that is the first time you met her Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Like I said I dont recall meeting her the first time I do remember her mother bringing her to the house Are you a member at Mar-a-Lago A No Have you visited Mar-a-Lago A Yes Did you visit Mar-a-Lago in the year A Im pretty sure I did When Ms Roberts arrived at the home with her mother what happened A I spoke to her mother outside of the house and she what I dont recall is exactly what happened because I was talking to her mother the entire she was in the house Did you introduce Ms Roberts to Jeffrey Epstein A I dont recall how she actually met Mr Epstein As I said I spoke to her mother the entire time outside the house Did you walk Ms Roberts up to the upstairs location at the Palm Beach house to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential meet Mr Epstein MR PAGLIUCA Object to the form and foundation You can answer A I just explained A I spent the entire time talking to Virginias mother outside the house so the answer to the question is no No did you not walk her up and introduce her to Mr Epstein A I just said no Did you participate in a massage this first time when she first came to the home and you were speaking with her mother she was in the home is that correct you brought her into the home MR PAGLIUCA Object to the form and foundation A I will repeat again I was standing outside with her mother so very difficult for me to do anything else at that time so no I did not take her upstairs Did you participate A Virginia lied percent about Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential absolutely everything that took place in that first meeting She has lied repeatedly often and is just an awful fantasist So very difficult for anything to take place that she repeated because I was with her mother the entire time So did you have did you give a massage with Virginia Roberts and Mr Epstein during the first time Virginia Roberts was at the West Palm Beach house MR PAGLIUCA Object to the form and foundation Yes or no A No Have you ever given a massage with Virginia Roberts in the room and Jeffrey Epstein MR PAGLIUCA Object to the form and foundation A No Have you ever given Jeffrey Epstein a massage MR PAGLIUCA Object to the form foundation And Im going to instruct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential you not to answer that question I dont have any problem with you asking questions about what the subject matter of this lawsuit is which would be as youve termed it sexual trafficking of Ms Roberts To the extent you are asking for information relating to any consensual adult interaction between my client and Mr Epstein Im going to instruct her not to answer because its not part of this litigation and it is her private confidential information not subject to this deposition MS McCAWLEY You can instruct her not to answer That is your right But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions This is civil litigation deposition and she should be responsible for answering these questions MR PAGLIUCA I disagree and you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential understand the bounds that I put on it MS McCAWLEY No I dont I will continue to ask my questions and you can continue to make your objections Did you ever participate from the time period of to did you ever participate in a massage with Jeffrey Epstein and another female MR PAGLIUCA Objection Do not answer that question Again to the extent you are asking for some sort of illegal activity as youve construed in connection with this case I dont have any problem with you asking that question To the extent these questions involve consensual acts between adults frankly theyre none of your business and I will instruct the witness not to answer MS McCAWLEY This case involves sexual trafficking sexual abuse questions about her having interactions with other females is relevant to this case She needs to answer these Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential questions MR PAGLIUCA Im instructing her not to answer MS McCAWLEY Then we will be back here again Have you ever given a massage to Mr Epstein with a female that was under the age of A Can you repeat the question Yes Have you ever given a massage to Mr Epstein with a female that was under the age of A No Have you ever observed Mr Epstein having a massage given by an individual a female who was under the age of A No Have you ever observed females under the age of in the presence of Jeffrey Epstein at his home MR PAGLIUCA Object to the form and foundation A Again I have friends that have children Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im not talking about friends Im talking about individuals MR PAGLIUCA Im going to object to you interrupting the witness who was answering your question The question was have you ever seen anyone female under the age of at the house and thats the question she was answering If you want to strike that question and ask another question feel free but let the witness respond please MS McCAWLEY I will do that Have you ever observed a female under the age of at Jeffrey Epsteins home that was not a friend a child one of your friends children A Again I cant testify to that because I have no idea what you are talking about You have no idea what Im talking about in the sense you never observed a female under the age of at Jeffrey Epsteins home that was not one of your friends children is that correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation A How would I possibly know how someone is when they are at his house You are asking me to do that I cannot possibly testify to that As far as Im concerned everyone who came to his house was an adult professional person Are you familiar with the police report that was issued in respect to the investigation in this matter MR PAGLIUCA Object to the form and foundation Are you familiar with the police report that was used in this matter the investigation of Jeffrey Epstein has been produced as a document in this matter A I have seen a police report Maxwell Exhibit police report marked for identification The police report that you have in front of you can you turn to page of that report the numbers are on the top right-hand corner Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential You will see some redactions in this report Ms Maxwell the redacted information is redacted because it reveals the name of a minor someone who is under the age of On page in the third paragraph about halfway down it says stated she performed the massage naked At the conclusion of this massage Epstein paid for the massage He explained I know you are not comfortable put I will pay you if you bring some girls He told her the younger the better stated once tried to bring a year old to Epstein and he stated the female was too old Have you heard Mr Epstein use the phrase the younger the better A I have no recollection of hearing that Have you used the phrase in talking to and asking her to recruit females for Mr Epstein the younger the better MR PAGLIUCA Object to the form Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and foundation of the question A First of all can you break the question apart Have you used the phrase the younger the better in speaking to and asking her to recruit females for Jeffrey Epstein MR PAGLIUCA Object to the form and foundation You can answer Its yes or no A No thats absolutely not true on the second part of your question I have not asked Virginia to recruit females and the first part of your question if you can repeat that again the question you asked Will you read back the question Record read A I believe I answered the later part of the question The first part of the question its impossible for me to recall events that took place years ago but it doesnt sound like something I would say On page that same paragraph was asked how many girls in total she Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential brought to Epstein stated that she can remember stated that she brought and its redacted there and the victim in this case Let me ask my question I have a question pending right now Are you testifying that you are unaware of any underage under the age of females coming to Jeffrey Epsteins home to perform massages MR PAGLIUCA Object to the form foundation A You need to straddle that question in a different time period When I was there at the time I was present the people that gave Jeffrey men and women who gave Jeffrey massages were adults over the age of Never in your time at any of Jeffrey Epsteins homes were you present when a female under the age of was there to give Jeffrey Epstein a massage MR PAGLIUCA Object to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A First of all as I said when I was present It is a yes or no A No it is not You can answer the question in full but please provide yes or no as an initial matter A I cannot answer yes or no its not bounded by time Its entirely possible I could have been in a room or even in the vicinity of Palm beach when somebody came and I would not know How would I know when somebody was in the house There is no way I can know Did you stay at Jeffrey Epsteins home when you were in Palm Beach A Most of the time So how is it that you wouldnt know if there was a female in the home under the age of if you were staying there A Well first of all when I was staying there the house is actually quite large and I have a very busy job and I had an office with a door so the door would be shut Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and I would be working Im not responsible for what Jeffrey does and I dont always pay attention to what happens in the house Im very busy So youre testifying that you never observed a female under the age of at Jeffrey Epsteins West Palm Beach home MR PAGLIUCA Object to the form and foundation A I already answered that question I believe You didnt answer my question A I did Did you observe a female under the age of at Jeffrey Epsteins home in Palm Beach A Like I said I work I dont sit there and watch people coming in and out of the house I cannot possibly tell you if Im in the home that somebody was there that I did not see I cannot comment on it I have no idea Did you observe females at Jeffrey Epsteins home that were laying out topless Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential in the back of the home in other words without a shirt on A So thats just another of Virginias lies So lets be clear at the time when I was there and present frequently at the house it was unusual to see people without their clothes on When you say unusual did you observe people without their clothes at Jeffrey Espsteins home A Can I answer Sometimes people in the privacy of a house and swimming pool I have seen people from time to time take their top off I have seen people from time to time do that Very unusual Naked people around the people at any frequent period of time I have never seen Were they under the age of A As I was saying people when I was in the house were of adult age if they were children friends of my family or friends that were there they may well have been because I have nieces and nephews under the age of I cannot testify to anybody else Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential just another one of Virginias many fictitious lies and stories to make this a salacious event to get interest and press Its absolute rubbish Were you in charge of hiring individuals to provide massages for Jeffrey Epstein A My job included hiring many people There were six homes As I sit here I hired assistants I hired architects I hired decorators I hired cooks I hired cleaners I hired gardeners I hired pool people I hired pilots I hired all sorts of people In the course and a very small part of my job was from from time to time to find adult professional massage therapists for Jeffrey When you say adult professional massage therapists where did you find these massage therapists A From time to time I would visit professional spas I would receive a massage and if the massage was good I would ask that man or woman if they did home visits Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you ever hire a masseuse that was under the age of MR PAGLIUCA Object to the form and foundation Did you A Again I dont hire massage therapists so that was not my job You just said you did you just said you hired massage therapists for Jeffrey Epstein Im asking if you hired a massage therapist who was under the age of A Let me correct myself When I meant hire I didnt mean hire in the way you are doing it What I say is that I went to spas and I met people and if they did home visits Jeffrey would then in fact hire them Im not responsible for hiring someone And they were not full-time so its not a correct characterization Did you ever your term is meet did you ever meet a person that was under the age of that you that Jeffrey then hired as a masseuse MR PAGLIUCA Object to the form Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and foundation A First of all Virginia Roberts who you are referring to was a masseuse aged we all now know so your story that you keep pushing out to the press that she was a year old you and I both know was a lie correct You are not sentencing my question A You and I both know that was a lie correct You are not answering my question Im asking you whether you ever met a female under the age of that Jeffrey then hired as a masseuse MR PAGLIUCA Object to the form and foundation A The only person I can talk about who clearly was a massage age a masseuse was Virginia Did you meet her and then introduce her to Jeffrey A I dont know I already testified I dont recall meeting her Maxwell Exhibit email marked Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential for identification So Im showing you a document that we have marked as Maxwell Exhibit Its a document you produced in this matter labeled confidential GM Its dated Sunday June Its from Jeffrey Epstein to you If you can turn to page sorry can you turn to the first page the cover page initially which is If you look under the time stamp it says June at p.m it says Is that your email address A It is Under that it says Thank you I have it now and Im working on a letter a little I will send the final version tomorrow and what ever it is will be factually accurate Do you see that on page A I do Then I would like you to turn to page please The second paragraph down on page it states After some thought I recall that I first met Ms Roberts when she Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential was working at a premier resort claiming to be years old and a professional masseuse MR PAGLIUCA What line are you on counsel MS McCAWLEY Second paragraph down MR PAGLIUCA I got it Is that a statement that you wrote A It appears to be So does that correct your testimony that you did meet Ms Roberts at Mar-a-Lago A Again this was written in when were you saying A So by Ms Roberts had already perpetrated so many lies and stories its hard for me to accurately tell you today what I remember back then As I sit here today the testimony I give you today I do not recollect it Do you have a reason to say that this document that you wrote is incorrect A Its in I cant possibly tell you what I remember in Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Are you questioning that this document is incorrect this document this email that you wrote A I wrote an email I was trying to be accurate so who knows with all the rubbish that you guys have put out in the press that I read maybe in the moment I wrote it a memory came to me that I dont know but as I sit here today and the testimony I gave you today is I dont recollect it Does this refresh your recollection that you recalled meeting Ms Roberts at Mar-a-Lago A It does not So your testimony today is that you dont remember meeting Ms Roberts at Mar-a-Lago A I do not I just want to clarify when you read so much stuff and so much rubbish that comes out from Virginia Roberts you dont know whats up and down at the time I wrote this I believe I had a memory but as I sit Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential here today I do not Ms Maxwell when did you first meet MR PAGLIUCA Object to the form and foundation A I have no idea when I met her Do you know how old she was when you met her A I have no idea how old she was when I met her Is it possible she was years old when you first met her MR PAGLIUCA Object to the form and foundation A may have been in the house when Jeffrey was in the house I have no idea how old she was I understand Im asking if was years old when you first met her A I have no idea Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Was she under when you first met her A I have no idea how old she was when I first met her Did she look like a child when you first met her A I dont remember what she looked like at the time she was in the house How many years have you known her A I can only recall the last time I saw her When was the first time you met her A Again I just told you I dont recall the first time I met her Did travel with you on Jeffreys planes A I wouldnt remember if was on the plane or not Did you ever have sex with A No Did you ever observe Jeffrey having sex with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No Were you aware that Jeffrey was having sexual contact with when she was years old MR PAGLIUCA Object to the form and foundation A I would be very shocked and surprised if that were true 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 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 Ive already testified that I have met her and that she was there I dont understand what your question is asking So you have never seen Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation Is that your testimony A I already said I dont recall all the times Ive seen her and I have no memory of that Have you ever seen in the house with Jeffrey Epstein MR PAGLIUCA Object to the form and foundation A I just told you I dont recall seeing Were you ever involved in an orgy with A No absolutely not Can you tell me do you know an individual by the name of A I do How did you meet A At some point she was a friend of Jeffreys and I recall meeting her at some point Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you hire her A First of all I dont hire girls like that so lets be clear I already testified to that and I have no idea what you are referring to When you say girls like that what do you mean A I hire people who are professional at the house You are asking if I hired somebody to do what I dont know what you are talking about I hired people to work in the homes What was Nadia Marcinkova doing MR PAGLIUCA Object to the form and foundation A I have no idea what Nadia Marcinkova was doing I didnt hire her and I dont know what you are referring to You met Nadia Marcinkova A I testified I did Did she work for Jeffrey Epstein A I have no idea what she did Have you flown on planes with Nadia Marcinkova Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont recollect I dont know if I did How many times have you flown on Jeffrey Epsteins planes A Too many times More than A I really couldnt tell you how many More than A Again I said I cannot tell you how many a lot How many times with A I already testified I have no idea How old was when she first became involved with Jeffrey A I have no idea Was she MR PAGLIUCA Object to the form and foundation A I have no idea Did she look like a child the first time you met her Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation Asked and answered Did she look like a child the first time you met A I dont know what you mean if she looked like a child Did she look like she was under the age of A No Did she look like she was under the age of A I just testified first of all I couldnt tell you how old she was she didnt like like a child leave it at that Did you know that she was a child MR PAGLIUCA Object to the form and foundation A I just answered I did not know how old she was and she looked like an adult In the times that you traveled with her on Jeffrey Epsteins planes did you ever ask her how old she was MR PAGLIUCA Object to the form and foundation Assumes facts not in Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential evidence The witness already testified she doesnt remember You can answer that question Did you ever ask her on the many flights you were with her or the many times you were with her at the house A First of all I dont know I was on many flights with her you are making stories up again as usual And secondly if I was on a flight with her there would not be any reason why I would ask her how old she was You dont recollect having any conversation with her about her age A I already testified to that Do you know what was hired to do for Jeffrey A I already testified I didnt know she was hired and I dont know that she did anything I dont know how to answer that question Was at the house the Palm Beach house when you were present at that house MR PAGLIUCA Object to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential foundation A I have no recollection of her being at the house at the same time as me When did you first meet A I already told you I dont recall Do you recall anything about A That she was tall and blond Do you recall interacting with other females at the house A No I do not Did you arrange to get a visa for to come into this country MR PAGLIUCA Object to the form and foundation A Absolutely not Did Jeffrey arrange for a visa for MR PAGLIUCA You need to give me a break so I can interpose an objection Object to the form and foundation You can answer A What was the question Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did Jeffrey arrange for a visa for A I dont know what Jeffrey did I cannot testify what Jeffrey did Was involved in sex with Jeffrey and other girls MR PAGLIUCA Object to the form and foundation Girls under the age of MR PAGLIUCA Same objection A I have no idea Was involved with sex with Jeffrey and girls over the age of MR PAGLIUCA Same objection A I have no idea Did recruit other girls for sex with Jeffrey MR PAGLIUCA Object to the form and foundation A I have no idea Do you still talk to A No A I have no idea Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have no idea Are you a pilot A I am Have you flown with A I have Have you flown with A What do you mean by flown Have you been on planes with her A I already testified I dont recall having her on a plane with me Do you know A I do When did you first meet her A I dont recall exact dates Did you meet her with the purpose of hiring her to work for Jeffrey or having Jeffrey hire her MR PAGLIUCA Object to the form and foundation A No What was her relationship with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Jeffrey MR PAGLIUCA Object to the form and foundation A I dont know exactly the nature of her relationship but she worked for him What did she do MR PAGLIUCA Object to the form and foundation A At the time she when was with him I believe she traveled with him and helped with his travel arrangements Did she bring girls to the house to give massages to Jeffrey MR PAGLIUCA Object to the form and foundation A I dont know what did So you never observed bringing girls to the home to give massages to Jeffrey MR PAGLIUCA Object to the form and foundation A I dont understand the question what did you mean bring Did you ever observe Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential inviting bringing walking anyone into the home to give a massage for Jeffrey MR PAGLIUCA Object to the form and foundation A I dont recollect anything like that Are you aware that was a co-conspirator named as a co-conspirator in the case involving Jeffrey Epstein MR PAGLIUCA Object to the form and foundation and also calls for a legal conclusion MS McCAWLEY Im just asking if she is aware of that A I am aware Who paid A I have no idea Did you ever arrange payment for any of the employees at the home MR PAGLIUCA Object to the form A What do you mean by arrange Were you ever in charge or responsible for paying individuals at the home that worked there Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A People had salaries and they were paid by the office Did you ever pay any individual did you ever hand an individual cash for work they performed MR PAGLIUCA Object to the form A Can you be more specific about what you are asking me Did you ever hand any individual who was working at the home cash as payment for something that they performed at the home MR PAGLIUCA Object to the form A To the best of my recollection there were very few times where I would leave some cash for people for work performed And what type of work was being performed where you would be doing that A If I left cash for the pool guy I would have left potentially some cash for the gardener potentially for exercise instructors and sometimes for massage therapy How much were the massage Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential therapists paid MR PAGLIUCA Object to the form and foundation A They get paid between and Did it vary based on what sexual acts they performed MR PAGLIUCA Object to the form and foundation A No It varied depending how much time some massage therapists charge more and some charge less Did the massage therapists that were hired to come to the home perform sexual acts for Jeffrey Epstein MR PAGLIUCA Object to the form and foundation A What are you asking me Im asking if the massage therapists A Are you asking me about underage girls Im asking in general did any of the massage therapists in the home A Are you asking if they were paid Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential for sexual acts Im asking if they performed sexual acts MR PAGLIUCA Object to the form and foundation Did any of the massage therapists who were at the home perform sexual acts for Jeffrey Epstein A I dont know what you mean by sexual acts Did any of the massage therapists who were working at the home perform sexual acts including touching the breasts touching the vaginal area being touched while Jeffrey is masturbating having intercourse any of those things MR PAGLIUCA Objection Form and foundation To the extent any of this is asking for to your knowledge any consensual sex act that may or may not have involved you Im instructing you not to answer the question Im not asking about consensual sex Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential acts Im asking whether any of the massage therapists performed sexual acts for Mr Epstein as I have just described A I have never seen anybody have sexual intercourse with with Jeffrey ever Im not asking about sexual intercourse Im asking about any sexual act touching of the breast did you ever see can you read back the question Record read A Im not addressing any questions about consensual adult sex If you want to talk about what the subject matter which is defamation and lying Virginia Roberts that you and Virginia Roberts are participating in perpetrating her lies Im happy to address those I never saw any inappropriate underage activities with Jeffrey ever Im not asking about underage Im asking about whether any of the masseuses that were at the home perform sexual acts for Jeffrey Epstein A I have just answered the question No you havent Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have No you havent A Yes I have You are refusing to answer the question A Lets move on Im in charge of the deposition I say when we move on and when we dont You are here to respond to my questions If you are refusing to answer the court will bring you back for another deposition to answer these questions Do you understand that MR PAGLIUCA You dont need to threaten the witness MS McCAWLEY Im not threatening her Im making sure the record is clear MR PAGLIUCA Certainly can you apply to have someone come back and the court may or may not have her come back again Again she is not answering questions that relate to adult consent Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential sex acts Period And thats the instruction and we can take it up with the court Ms Maxwell are you aware of any sexual acts with masseuses and Jeffrey Epstein that were nonconsensual A No How do you know that A All the time that I have been in the house I have never seen heard nor witnessed nor have reported to me that any activities took place that people were in distress either reported to me by the staff or anyone else I base my answer based on that Are you familiar with a person by the name of A I am Has given a statement to police about you performing sexual acts on her A I have not heard that Has given a statement to police about Jeffrey Epstein performing Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential sexual acts on her MR PAGLIUCA Object to the form and foundation A I have not heard that How do you know A Was under the age of MR PAGLIUCA Object to the form and foundation A I dont recall how old was Did she tell police that Jeffrey Epstein assaulted her sexually MR PAGLIUCA Object to the form and foundation A I never heard that Did recruit or bring girls to the home that were under the age of MR PAGLIUCA Object to the form and foundation and I think this has been Case Document Filed Page of I I MAGNA9 LEGAL SERVICES Page Maxwell Confidential asked and answered already You can answer the question A I have no idea what did You never observed with girls under the age of at Jeffreys home MR PAGLIUCA Object to the form and foundation A The answer is no I have no idea Do you know A I do What is your relationship with MR PAGLIUCA Object to the form A What do you mean what is my relationship Are you friendly with him how do you know him A He is the husband of Is one of your friends A Yes Did you ever send Virginia to to give him a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential massage MR PAGLIUCA Objection to the form and foundation A No Did you ever instruct Virginia Roberts to have sex with MR PAGLIUCA Objection to the form and foundation A I have never instructed Virginia to have sex with anybody ever How old was when she met Jeffrey MR PAGLIUCA Objection to the form and foundation A I have no idea Whats she under the age of MR PAGLIUCA Objection to the form and foundation A I just testified I have idea how old she was You testified she was your friend You dont know how old she was when she met Jeffrey A That happened sometime in the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential how would I know or I have no idea Can you testify to what your friends did years ago You dont ask the questions here Ms Maxwell What about when did you first meet A I dont recall the exact date Did you hire A I dont hire people she came to work at the house to answer phones Where did you meet her A I just testified I dont recall exactly when I met her Was one of your job responsibilities to interview people that would be then hired by Jeffrey A That was one of my responsibilities Do you recall interviewing A I dont recall the exact interview no Do you know what tasks was hired to performance Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A She was tasked to answer telephones Did you ever ask her to rub Jeffreys feet MR PAGLIUCA Objection to the form and foundation A I believe that I have read that but I dont have any memory of it Did you ever tell that she would get extra money if she provided Jeffrey massages A I was always happy to give career advice to people and I think that becoming somebody in the healthcare profession either exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity Hourly wages are around and as a professional healthcare provider you can earn somewhere between as we have established to and to be able to travel and have a job that pays that is a wonderful job opportunity So in the context of advising people for opportunities for work it is possible that I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential would have said that she should explore that as an option Did you tell her she would get extra money if she massaged Jeffrey A Im just saying I cannot recall the exact conversation I give career advice and I have done that Did you ever have massage you A I did How many times A I dont recall how many times Was there sex involved A No Did you ever instruct to massage A I dont believe I have no recollection of it Did you ever have sexual contact with MR PAGLIUCA Object to the form and foundation You need to give me an opportunity to get in between the questions Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Anything that involves consensual sex on your part Im instructing you not to answer Did you ever have sexual contact with A Again she is an adult Im asking you did you ever have sexual contact with A Ive just been instructed not to answer On what basis A You have to ask my lawyer Did you ever have sexual contact with that was not consensual on part MR PAGLIUCA You can answer nonconsensual A Ive never had nonconsensual sex with anybody Not MR PAGLIUCA Objection A I just testified I never had nonconsensual sex with anybody ever at any time at anyplace at any time with anybody Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential So if were to testify that she did not consent to a sexual act that you participated in A I just told you I have never ever under any circumstances with anybody at any time in anyplace in any form had nonconsensual relations with anybody Did you introduce MR PAGLIUCA Objection to the form and foundation A Ive again read that claimed that she met or that she said she met I dont know if I was the one who made the introduction or not Do you know a female by the name of A I do How do you know her A So she worked for you A Yes Did you hire her A Again Jeffrey hired people Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you have sex with her MR PAGLIUCA This is the same instruction about consensual or nonconsensual Was under the age of when you hired her A No I didnt hire her as I said Jeffrey did Did ever have sex with Jeffrey MR PAGLIUCA Objection to the form and foundation A How would I know what somebody else did You werent involved in the sex between Jeffrey and yourself A We already Were you involved with sex between Jeffrey and yourself MR PAGLIUCA Everyone is talking over each other You heard the question Again you you know what the instruction is If there is any Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential consensual issue involved I instruct you not to answer A Moving on So you are refusing to answer that question A Ive been instructed by my lawyer Did you ever have sex with Jeffrey Virginia and yourself when Virginia was underage A Absolutely not MR PAGLIUCA Weve been going for about an hour I would like to take a five-minute break please MS McCAWLEY Im almost done MR PAGLIUCA You are not going to allow a break MS McCAWLEY As soon as I get through my line of questioning which is perfectly appropriate Did travel with you and Jeffrey to Europe A Im sure she did What is she doing today A I have no idea Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you speak to her regularly now do you speak to her A No Do you know where she lives A No Do you know what country she lives in A No Where is the last place you knew that she lived A Last place I knew for sure was in Los Angeles When did she stop working for you A What tasks did she performance for you A She helped me with moving in and out of houses construction she was a general help she helped with buying things that needed to be purchased if I needed her to stand in for me during meetings it was a very wide ranging job Did she ever bring females to perform massages for Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A What are you asking me Did was it ever responsibility to bring females to the house for the purposes of massaging Jeffrey A job was to help me with the houses and work in homes It was not her job to whatever you just said bring masseuses Did she do that A I have no recollection I have no idea Did you pay or did Jeffrey pay her A Jeffrey Do you recall how much she was paid A I do not MS McCAWLEY I think we can take a break now THE VIDEOGRAPHER Its and we are off the record Recess THE VIDEOGRAPHER Its now Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential We are back on the record and starting disk No Ms Maxwell I asked you about Virginia Roberts earlier Can you describe what Virginia Roberts duties were when she was with Mr Epstein MR PAGLIUCA Objection to the form and foundation A I believe that Virginia was a masseuse Was Virginia required to dress up in any way for massages MR PAGLIUCA Objection to the form and foundation A I have no idea Did you provide Virginia with outfits to wear for certain massages A I have no idea what you are talking about For example did you ever provide Virginia with a school girl outfit to wear for a massage A I have no idea what you are talking Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential about So you didnt provide her with that A As I just testified I have no idea what you are talking about I was trying to interpret whether you didnt understand what a school girl outfit was or you are saying that didnt happen A I clearly know what a school girl outfit is I have no recollection of providing anybody with a school girl outfit Did you have a set of outfits used by the massage therapists that would include things like a school girl outfit or a black patent leather outfit or anything of that nature MR PAGLIUCA Object to the form and foundation A That would be just another one of Virginias lies You didnt have anything like that A I did not Did you have a basket of sex toys Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that you kept in the Palm Beach house MR PAGLIUCA Objection to the form and foundation A First of all what do you mean A laundry basket that contained sex toys in it MR PAGLIUCA Objection to the form and foundation A Can you ask the question again Did you have a laundry basket that contained sex toys in it in the Palm Beach House MR PAGLIUCA Objection to the form and foundation Did you have a laundry basket of sex toys in the Palm Beach house MR PAGLIUCA Same objection You can answer A I dont recollect anything about a laundry basket of sex toys Do you recollect having sex toys at the Palm Beach house A You have to define what are you talking about Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A sex toy meaning a vibrator of some kind sometimes they are called dildos of that nature anything like that A I dont recollect anything that would formally be a dildo anything like that How would you describe sex toys A I wouldnt describe sex toys Did you have anything that was of an electronic nature that would be used during sex MR PAGLIUCA Objection to the form and foundation A I have no idea what you are referring to Maxwell Exhibit transcript marked for identification Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Case Document Filed Page of I I I I I I MAGNA9 EG A ER ICES Page Maxwell Confidential Case Document Filed Page of I I I I I I I I MAGNA9 EG A ER ICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A First I have to read this Sure MS McCAWLEY I will stop the clock while the witness is reading MR PAGLIUCA No MS McCAWLEY Yes if she is going to read the whole document I will stop the clock MR PAGLIUCA If you give her documents to refresh her recollection we are on the clock here MS McCAWLEY Then we will take it up with the judge MR PAGLIUCA Read whatever you need to answer the question MS McCAWLEY Im going to set the document aside and Im just go to ask you a question independent of the document Case Document Filed Page of I I MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you recall having a basket full of sex toys A I already told you I did not We were talking a moment ago about Ms Roberts and her position as a masseuse do you know what she was paid for working as a masseuse for Jeffrey Epstein A I do not Did you ever pay her A I dont ever recall paying her Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts MR PAGLIUCA Objection to the form and foundation A No Were you ever present to view a massage between Jeffrey Epstein and Virginia Roberts A I dont recollect ever seeing Virginia and Jeffrey in a massage situation Do you ever recollect seeing them in a sexual situation A I never saw them in a sexual Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential situation Did you ever participate in sex with Virginia Roberts and Jeffrey Epstein A I never ever at any single time at any point ever at all participated in anything with Virginia and Jeffrey And for the record she is an absolute total liar and you all know she lied on multiple things and that is just one other disgusting thing she added Did you help her obtain an apartment in Palm Beach to live in MR PAGLIUCA Objection to the form and foundation Was that part of your responsibilities for Jeffrey A First of all I didnt know she had an apartment in Palm Beach I only learned that from the many times you guys have gone to the press to sell stories so no Did you help her get a cell phone was that one of your responsibilities for Jeffrey to get her is a cell phone as part of her masseuse obligations Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I dont know what that means masseuse obligation I dont know what you are referring to Would you like to ask the question properly I think it was proper I will ask it again Did you ever assist in getting Virginia Roberts a cell phone to use during the time that she worked for Jeffrey Epstein A I have no recollection of doing anything of that nature Did you ever tell Virginia that you wanted her to have a cell phone so that she could be on call regularly A I have no recollection of that conversation How often would Virginia come over to the house in Palm Beach to give massages MR PAGLIUCA Objection to the form and foundation A Ask the question again please How often did Virginia Roberts come Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential over to the house in Palm Beach to give massages A Its important to understand that I wasnt with Jeffrey all the time In fact I was only in the house less than half the time so I cannot testify to when I wasnt in the house how often she came when I wasnt there What I can say is that I barely would remember her if not for all of this rubbish I probably wouldnt remember her at all except she did come from time to time but I dont recollect her coming as often as she portrayed herself How many times a day on an average day would Jeffrey Epstein get a massage MR PAGLIUCA Objection to the form and foundation A When I was at the house and when I was there with him he received a massage on average about once a day Just once A Yes Were there days when he received Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential four or five MR PAGLIUCA Objection to the form and foundation A When I was present at the house I never saw something like that Do you know if Virginia was required to be on call at all times to come to the house if Jeffrey wanted her there MR PAGLIUCA Objection to the form and foundation A I have no idea of the arrangements that Virginia made with Jeffrey When Virginia was in New York would Virginia sleep at Jeffreys mansion in New York MR PAGLIUCA Objection to the form and foundation A I dont recollect her being in New York and I have no idea where she slept You dont ever remember seeing Virginia Roberts in New York MR PAGLIUCA Objection to the form and foundation A I would barely recollect her at Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential all except for this story Do you recall Virginia Roberts calling you because she was having a medical crisis and you and Jeffrey taking her to the hospital A I have heard this absurd story and if any part of it were true I would remember that I do not You dont remember taking her to the hospital A Its not that I dont remember it it didnt happen How do you know it didnt happen A Thats the sort of memory you would recall Do you recall you said you dont remember her being at the New York mansion When you were in New York would you stay at the New York mansion with Jeffrey A I stayed from time to time Do you recall Virginia being at the New York mansion when came to visit MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A Like I told you I dont recall her being at the house at all How many homes does Jeffrey have MR PAGLIUCA Objection to the form and foundation A When I was working for him I think he had six maybe Would Virginia stay with him in those homes MR PAGLIUCA Objection to the form and foundation A I can only testify for when I was present with him and I cannot say what she did when I wasnt present with him When you were present would Virginia stay in the homes with him A I dont recall her staying in the houses Did you train Virginia on how to recruit other girls for massages MR PAGLIUCA Objection to the form and foundation A No Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you train Virginia on how to recruit other girls to perform sexual massages MR PAGLIUCA Objection to the form and foundation A No And its absurd and her entire story is one giant tissue of lies and furthermore she herself has if she says that you have to ask her about what she did Does Jeffrey like to have his nipples pinched during sexual encounters MR PAGLIUCA Objection to form and foundation A Im not referring to any advice on my counsel Im not talking about any adult sexual things when I was with him When Jeffrey would have a massage would he request that the masseuse pinch his nipples while he was having a massage A Im not talking about anything with consensual adult situation What about with underage A I am not aware of anything You are not aware of Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epstein ever having sex with an underage minor and asking them to pinch his nipples A I am not So Im going to direct you to I believe its Maxwell Exhibit the police report Are you aware that over under age minors gave testimony to police that they were engaged in sexual acts during quote-unquote massages MR PAGLIUCA The witness needs to find Exhibit Exhibit if you can hand me that please So now with respect to the police report are you aware that over underage girls meaning under the age of gave reports to police that they were assaulted sexually by Jeffrey Epstein during massages MR PAGLIUCA Objection to the form and foundation A I read the police report Thats all I can testify to Are you aware of what is in the police report Are you aware that there were Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential girls A I did not count the number of girls and I did read the police report I can only testify to what I read So you are aware that the police report contains reports from underage girls A I cant testify to what the girls said I can only testify to the fact that I read a police report that stated that Were you working for Jeffrey you said you worked for him off an on until is that correct A I helped out from time to time So you were working with him during the time period when these underage girls were visiting Jeffreys home MR PAGLIUCA Objection to the form and foundation A I was not what year I need years How about lets say A Im not sure I was at the house at all in maybe one day maybe Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential How about A I was present for his mothers his mother died in so I was there for his mothers death and the funeral and I was at the house maybe a handful of days again I would like to direct you to you have it pulled together now its page Bates stamped Giuffre A Can you repeat that please Sure A Yes At the top of that document about three lines down you see the redacted portions where there is black so it blacks out the name A I see black redacted portions Thats a black redaction of the name of the minor and there is I will represent for the record thats what it is You can contest that but Im not asking about the name of the minor Five lines down it says She was just years of age Do you see that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have to read that if you want me to testify to some things Im asking if you see where it says She was just years old A No I have to read it Its five line downs on the first paragraph A I do see that Then the next paragraph down it says this is the next full paragraph it says Epstein entered the room introduced himself Epstein lay on the table and told her to get comfortable blank could not remember if he was naked or if he entered the room with a towel Blank stated she provided the massage wearing her panties She continued rubbing his thighs and feet Blank advised he turned over on his back and continued to rub his legs with oil Epstein touched her breast and began to masturbate I asked if she knew what circumcised and uncircumcised meant She stated circumcised is when the penis had no foreskin Then jumping down to the next Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential paragraph it says Blank became upset crying hysterically and stated she was paid and also instructed to have sex with Epstein and by Epstein Do you see that there A I do Are you aware that there were underage minors in the Palm Beach house that were required to give sexual massages to Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation This has been asked and answered already Now you are just reading a document MS McCAWLEY I am allowed to take this deposition A I already testified Are you aware there were underage girls of them in this police report that were assaulted by Jeffrey Epstein in the Palm Beach house during the time you are working there A I am aware that Virginia has lied repeatedly Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im not asking about Virginia Im asking if you are aware that there were over underage girls who gave reports to police officers during the time you worked for Jeffrey Epstein Are you aware of that MR PAGLIUCA Counsel what is your factual basis for asserting there are underaged people who gave reports MS McCAWLEY I dont have to answer that MR PAGLIUCA Are you representing as an officer of the court that you have personal knowledge that there are people referenced in these police reports MS McCAWLEY Thats my understanding that there are girls MR PAGLIUCA How is that your understanding if these are redacted reports MS McCAWLEY By reading through the reports MR PAGLIUCA So you have personal Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential knowledge there are people MS McCAWLEY Just like can you if you read through I will not argue with you counsel she can answer yes or no Are you aware there were over individuals who were minors who gave reports to police just like the one we just read that they were sexually assaulted by Jeffrey Epstein in the Palm Beach home during the years that you were working with him MR PAGLIUCA Objection to the form and foundation You can answer if you have knowledge A I already testified I was limited in the house a couple of days there is no way I knew I have read these reports I cannot testify to Given the experience Ive had with Virginias lies its very hard for me to testify about what I see I can tell from you my personal knowledge I did not know what you are referring to You did not know there were underage girls in the home that were being Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential assaulted by Jeffrey Epstein during the time you were working there A Based on the lies that I have already been told I cannot comment on any Are you saying these girls are lying when they gave these reports to police officers A Im not testifying to their lies Im testifying to Virginias lies I am not asking about Virginias lies A I can only testify to Virginias lies I can testify to having read these reports I cannot testify to anything else about them So your testimony is that during the time you were working there you did not know that these minor children were being abused in the home while you were there A What I have already told you and I will repeat I was in the house very limited times very few times I do not know what you are referring to Ive read these reports but based on the lies that Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential has perpetrated cannot tell you what is true or factual or not You said you were in the home a very limited time so average in the year for example how many times would you have been in his Palm Beach home A Very hard for me to state but very little How about his New York home A Same Were you his girlfriend in that year in A Define what you mean by girlfriend Were you in a relationship with him where you would consider yourself his girlfriend A No Did you ever consider yourself his girlfriend A Thats a tricky question There were times when I would have liked to think of myself as his girlfriend When would that have been A Probably in the early Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential In your responsibilities in working for Jeffrey would you book massages for him on any given day so that he would have a massage scheduled Would you take a call for example and book a massage for him MR PAGLIUCA Objection to the form and foundation You can answer A Typically that was not my responsibility He would either book the massage himself or one of his other assistants would do that From time to time you had to do that MR PAGLIUCA Objection to the form and foundation A Like I said typically it was somebody elses responsibility If you were unable to book a girl for a massage on a given day would that mean that you were responsible for giving him a sexual massage MR PAGLIUCA Objection to the form and foundation and I instruct you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential not to answer any questions about any of your consensual adult sexual activity So you are not going to answer that question A You just heard my counsel 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 Have you ever said to anybody that you recruit girls A Stop right there I never recruited girls lets stop there Now breakdown the question 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 Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im asking the questions I know what this case is about Im trying to I will ask you questions if you dont understand the question I can break it down for you Im happy to do that A Break it down a lot please I will do that The question is have you ever said to anybody that you recruit other girls A Why dont you stop there Let me finish my question Have you ever said to anybody that you recruit girls to take the pressure off you so you wont have to have sex with Jeffrey have you said that Thats the question A You dont ask me questions like that First of all you are trying to trap me I will not be trapped You are asking me if I recruit I told you no Girls meaning underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of 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 dont know what you are saying about that and your implication is repulsive Answer my question A I just did Have you ever said to anybody that you recruit females A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential testify to actual language So you wont testify to anything Im asking you years ago about a statement you made How do you know its years ago A We are talking about a time in right Have you ever said that to anybody A Im years old so you are asking me in my entire life what words are you asking me in my entire life Your entire life is limited by the time you were with Jeffrey this is the question A Lets time limit the question you are asking me So from lets say I think you said you started with him in is that correct and finished with him in So from to have you ever said to anybody that you recruit other and we will start with girls to take the pressure off you to have sex with Jeffrey MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A First of all I resent and despise the world recruit Would you like to define what you mean by recruit and by girls you mean underage people I never had to do anything with underage people So why dont you reask the question in a way that I am able to answer it Im asking if you ever said that to anybody So if you dont understand the word recruit and you never used that word then the answer to that question would be no A I have no memory as I sit here today having used that word Did you ever meet an underage girl in London to introduce her to Jeffrey to provide him with a massage MR PAGLIUCA Objection to the form and foundation A Run that past me one more time Did you ever meet an underage girl in London to introduce her to Jeffrey to perform a massage MR PAGLIUCA Same objection A Are you asking me if I met anybody Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that was underage in London specifically to provide a massage to Jeffrey is that your question Yes A No Do you know who is A I dont recall her right now Do you know if strike that During the time that you were working for Jeffrey did you ever observe any foreign females so in other words not from the United States that were brought to Jeffreys home to perform massages MR PAGLIUCA Objection to the form and foundation A Females what age are we talking Any age A Can you repeat the question During the time you were working for Jeffrey did you ever observe any foreign females of any age that were at Jeffreys home to perform a massage MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Are you asking me if any foreigner not an American person gave Jeffrey a massage Yes A Well as I sit here today I cant think of anyone who is foreign Certainly I just cant think of anybody right this second How about any foreign girls who were under the age of A I already testified to not knowing anything about underage girls Were there foreign girls who were brought to Jeffreys home by for the purposes of providing massages MR PAGLIUCA Objection to the form and foundation A I am not aware of bringing girls I have not no idea what you are talking about You have never been around foreign girls who are under the age of at Jeffreys homes MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I already testified about not knowing about underage girls Did you provide any assistance with obtaining visas for foreign girls that were under the age of A Ive never participated in helping people of any age to get visas Did Jeffrey was it Jeffreys preference to start a massage with sex MR PAGLIUCA Objection to the form and foundation A I think you should ask that question of Jeffrey Do you know A I dont believe that was his preference I think you have to understand a massage perhaps you are not really familiar with what massage is I am I dont need a lecture on massage A I think you do MR PAGLIUCA No question pending She will ask you another question now Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Massage is for health benefits When did you first meet Jeffrey A Some point in And did Jeffrey know your father A No How were you introduced to Jeffrey A Some friend introduced us Can you describe your relationship back in was it friendship or was it girlfriend relationship or was it a work relationship what was your relationship in A It was just friendly Then I believe you testified you began working for him in is that correct A Yes In I know you gave me the description of the work that you were performing for him how much was he paying you do you remember A I dont recall Do you know for example in how much he was paying you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont recall Did it change over the years or did the payment remain the same A I believe over the course of time it increased a little bit Was that the was that payment the payment that was the payment made with respect to the jobs the work you were performing for Jeffrey was that your sole income at that time MR PAGLIUCA I object to the form Im also going to instruct you not to answer about sources of your personal sources of income outside of Mr Epstein at all MS McCAWLEY Whats the basis for that MR PAGLIUCA Its confidential its not part of this lawsuit MS McCAWLEY We have a protective order and it is part of this lawsuit with respect to our damage claims MR PAGLIUCA Its not and in fact you are not entitled to ask Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential financial information of a defendant in this kind of case in a defamation case unless and until there is a finding that you are entitled to punitive damages That is clear in New York case law both state and Federal MS McCAWLEY We disagree on that point and we will come back to that From the source of payment from the source of Jeffrey from your work can you give me a range on that do you know was it over A I just testified I dont recall You dont dont know if it was A It was less than that Somewhere between and would that be fair to say A I believe it was between and Did Jeffrey during the time that you were working for him purchase a town home for you A The subject of the townhouse is I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential worked for it and I had a loan we did loans So a loan through Jeffrey A I dont recall the exact transaction Did he purchase for you a helicopter during the time you were working for him A It was his helicopter When did you obtain your pilot license A I believe it was or Was that for both airplanes and helicopters or just helicopters A Just helicopters Have you ever flown on your helicopter A That is another one of Virginias lies The question is have you ever done that A I have never flown at any time ever in any helicopter in any place any time in any state in any country at any time anywhere Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Have you ever had dinner with at Jeffreys home at any of Jeffreys homes A No I dont believe so Have you traveled on Jeffreys planes with A Yes I have Would that have been in A Its very hard for me to recollect exact dates but that sounds about right Was that during the time that Virginia was working for Jeffrey A I dont know that Virginia ever did work for Jeffrey I dont exactly know if she testified to her so-called duties we know she is a serial liar so I cant testify to what she did or didnt do So I object to that characterization of her So repeat the question please Can you read the question back Record read You can answer the question A What was the question again When you were traveling on the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential plane with was that during the time it was that you were on a flight with was that during the time Virginia was working for Jeffrey MR PAGLIUCA Object to the form Misstates the witness answer and if you can answer the question you can answer it A Well like I said I dont recall exactly when I flew with him I dont recall when Virginia we know what Virginia claims when she left so I cant answer the question I have no idea Do you know A I do How long have you known him A A very long time Since you were a child A I really its so long its really a long time ago I just dont recall Do you remember how you first met him A No I do not Did you introduce him to Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A That would be another of Virginias lies and the lies you perpetrate I never introduced to Jeffrey Epstein at any time ever so just add that the to long list of lies Did Jeffrey know A Clearly he knew him I think we have that answer but how yeah Do you know how Jeffery met A I do not know Jeffrey met What I do know is that I did not introduce them That is one of the many lies Are we tallying all the lies Do you know when Jeffrey met A I do not know when Jeffrey met Did you ever introduce to any girls under the age of who were not friends of yours children A I have not introduced to anyone that I am aware of other than friends of mine who have kids under that age Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that he may have met socially through me Did you ever introduce to Virginia in London A I understand her story about but again her tissue of lies is extremely hard to pick apart what is true and what isnt Actually I wouldnt recollect her at all but for her tissue stories about this situation So did you ever introduce to Virginia in London A I have no recollection Did Virginia ever stay at your home in London your town home A I know she claims she did but if you are asking me here today to remember specifically I cannot Do you remember taking a trip with Virginia to travel over to Europe including London A So I have seen her reports and I have seen the plane reports I see she says she was on that but again I really have no recollection of her Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you know that she was at the time of that trip MR PAGLIUCA Objection to the form and foundation A I have Did you know she was at the time of that trip MR PAGLIUCA Objection to the form and foundation A I didnt even know she was on the trip Did you hold her passport for her when she was traveling MR PAGLIUCA Objection to the form and foundation A I have no recollection whatsoever of her even being on the trip nor holding her passport Maxwell Exhibit picture marked for identification Im showing you what we marked as Maxwell Exhibit Can you take a look at that picture for me Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Ive looked at it Are you in that picture A I am A It is MR PAGLIUCA I dont believe this has been produced to us in discovery by you MS McCAWLEY The picture MR PAGLIUCA Yes MS McCAWLEY It has MS MENNINGER Is it the same exact photograph MS McCAWLEY I believe so We will find one The picture has been produced a number of times MR PAGLIUCA Ive seen different iterations of this I dont believe I have ever seen this MS McCAWLEY We had them blow it up on a page so she could see it We could use an article While you are looking for that I Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential will skip ahead Hold that until we can find one that has the Bates range on it Do you recall Virginia being at your London town home A I do not Do you recall going to dinner with Jeffrey Epstein and Virginia Roberts in London at any time A I do not Do you recall going to a place called Jeffrey Epstein and yourself and Virginia Roberts A I would just like to state for the record I do not have any recollection of it and I doubt it actually happened You dont recall that Do you recall taking Virginia shopping when you were in London to buy an outfit to meet Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No I dont Where in your town home we will come back to that Do you have guest bedrooms in your town home in London A I do How many A Two Did ever visit Jeffrey and you in New York A Yes Do you remember him visiting you and Jeffrey in New York in the spring of A Again I cant testify to any specific dates So you dont have a recollection of that A I have a recollection youve asked me if I have a recollection of being in New York but if you are asking for a date I cannot confirm that date Do you remember being present in New York for a party where Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential was also present A I dont recollect Do you recall ever giving a gift of a puppet that was in the same that looked like him A I never gave him a gift of a puppet Did Jeffrey ever give him a gift of a puppet A No not that I am aware of Have you ever given him any gifts MR PAGLIUCA Objection foundation A I know Have you ever given him any gifts that you remember when he came to Jeffreys home in New York A I dont recall giving him any gifts in New York Maxwell Exhibit picture marked for identification I think I directed you to page Is that a picture that was taken at Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential your London town home A I have no idea what this picture was taken I know what she purports it to be but Im not going to say that I do Do the surroundings look like your London town home A They are familiar Do you know who took this picture A I do not Did Jeffrey Epstein take the picture A I just testified I dont know who took the picture So you dont know if Jeffery Epstein took the picture A When I tell you I dont know who took the picture it doesnt mean him I dont know who took the picture You can come up with names I still do not know who took the picture Did you observe go into a room with Virginia alone in your town home A I cannot recall As I have said Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential no Did ever tell you that he had sex with Virginia Roberts A He did not Did Jeffrey Epstein ever tell you that had sex with Virginia Roberts A He did not Did ever visit let me back up for a moment We talked about Jeffreys homes did Jeffrey have a home in the U.S Virgin islands called Little St James A Yes Did ever visit that island are you aware of ever visiting Jeffreys island A I am aware of that yes Do you know how many times he visited A I do not Do you know if he visited when Virginia was on the island A I do not Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Were you present on the island when visited A Yes How many times A I can only remember once Were there any girls under the age of on the island during that one visit that you remember that were not family or friends of or daughters of your friends MR PAGLIUCA Objection to the form and foundation A There were no girls on the island at all No girls no women other than the staff who work at the house Girls meaning I assume you are asking underage but there was nobody female outside of the cooks and the cleaners Did you as part of your duties in working for Jeffrey ever arrange for Virginia to have sex with MR PAGLIUCA Objection to the form and foundation A Just for the record I have never at any time at anyplace in any moment ever Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential asked Virginia Roberts or whatever she is called now to have sex with anybody Did you ever provide Virginia Roberts with an outfit an outfit of a sexual nature to wear for MR PAGLIUCA Objection to the form and foundation A I think we addressed the outfit issue I am asking you if you ever provided her with an outfit of a sexual nature to wear for A Categorically no You did get that I said categorically no Dont worry Im paying attention A You seemed very distracted in that moment Maxwell Exhibit flight logs marked for identification A Do you mind if I take a break for the bathroom Its and we are going to go off the record now THE VIDEOGRAPHER Its now Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential We are off the record Recess THE VIDEOGRAPHER Its now we are back on the record and starting disk No Ms Maxwell I think I handed you right before the break did I hand you the flight logs they look like this Did I mark those yet I thought I did A I dont believe I have it These admittedly are a little difficult to read so what Im going to provide you with to assist is I have a chart that has the airport codes because it will have for example just for the record reflects that the first page of document it will have a code in the from line that says PBI for example to TEB so I a chart that matches up just in case you dont understand what those letters mean PBI meaning Palm Beach TEB meaning Teterboro which is New Jersey but others are more difficult but just for you to be able to understand the logs I will provide you with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that MR PAGLIUCA So we are clear if the witness has personal knowledge of what these are thats fine but I dont know what these are and I dont expect the witness to accept the representation that they are what they are MS McCAWLEY If she can testify to what city it is she can state that on the record MR PAGLIUCA If she knows what it is she knows what it is we are not putting any affirmatively on the record until you ask your questions So Im going to ask you and I think we flagged a few of the pages which may direct us a little bit easier but I will do it by Bates number which is at the bottom of the document kind of at the side The first I will direct your attention to is A Does it have a tab It should Let me make sure A Yes it does Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential So Im directing your attention to the bottom two lines up from the bottom there is a flight MR PAGLIUCA Are you on MS McCAWLEY So this flight is from the one Im looking at I think its highlighted on your copy On the far corner on the date it says at the top and this would be the and then the are the two Im going to direct your attention to On that first one on the you will see the column reading PBI in the from column to TEB in the to column and you will see some initials you will see JE for Jeffrey Epstein GM for Ghislaine Maxwell for and then Virginia A I have to object MR PAGLIUCA You dont get to object She is turning into a lawyer already A I would like to Let me ask the question and if you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential have an issue so with respect to this flight do you recall being on a flight in the going from Palm Beach to Teterboro A No I dont recall any specific flight Do you recall flying with Virginia on a flight with and Jeffrey Epstein at any time A I dont How often did you fly on a plane with a year old MR PAGLIUCA Objection to form and foundation A I have no idea what you are talking about other than friends of mine that had kids Did you regularly fly on Jeffreys plane with individuals who were under the age of MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Did you regularly fly on Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epsteins planes with individuals who were under the age of A I regularly flew on Jeffrey Epsteins airplane but I cannot testify as to flying with people under the age I dont believe that I did Why wouldnt you remember flying with a year old MR PAGLIUCA Objection to the form and foundation A How would I know one that she is how would you know that how do you know Im on the plane Are you saying you are not on this flight so this is a Palm Beach to Teterboro This says the JE GM and Virginia The GM you are saying is not you MR PAGLIUCA I object to the form You can answer the question if you know A How do you know the GM is me Is it your testimony that on the flight logs when it represents GM that it is not you flying on the plane Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A GM can stand for any level it could be Georgina George Are there any people that flew with Jeffrey Epstein that had the initials GM A I dont know Do you recall flying with Jeffrey Epstein on his plane over times during the period of to A I cannot testify to how many times I was on his plane because that would just be impossible You were on his plane regularly would you say A I already testified I was on his plane regularly Is it your testimony and Im referring now to the line that we were just talking about that you were not on the flight from Palm Beach to Teterboro that lists JE GM and Virginia A I am not testifying to that I am just saying that you cannot be sure that is Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential me So as you sit here today you dont believe you flew on that plane A Im not saying that Im just saying you cannot be sure thats me Do you have reason to doubt that when it says GM on these flight logs that that represents you A I cannot testify to that Im just saying it may not be me In looking at the flight logs and look up lets move up a couple of lines If you start at the top you are going to see JE then JE JE JE GM JE GM JE GM reposition JE GM JE GM JE GM female repositioning JE GM JE GM JE GM Virginia JE GM Virginia repositioning and then a certification So is it your testimony in looking at that that you do not believe that the GM Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential represents you MR PAGLIUCA Objection to the form and foundation A Im not saying that Im just saying that you cannot I cant sit here and tell you for sure GM is me and I cannot testify remembering being on a flight at that time You dont remember being on any of these flights with the initial GM A I remember being on many flights I cannot testify that is a flight I am on Lets go to the next page which is going to be I want you to look at line so the date is at the top so its and if you go down you will see a line that says the and if you scroll over you will see PBI to TIST if you look at the airport codes TIST is going to be representative for the U.S Virgin Islands and then you will see the list on the plane JE GM and Virginia Roberts Do you recall flying from Palm Beach to the U.S Virgin Islands with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Jeffrey yourself and Virginia Roberts MR PAGLIUCA I object to the form and just so the record is clear we dont agree with whatever your characterizations are The document speaks for itself and she can answer based on whatever her personal knowledge is MS McCAWLEY I understand Do you recall flying with those individuals from Palm Beach to the U.S Virgin Islands A I have no recollection of any individual flight you are pointing out here You are talking about how many years ago is that Im asking the questions A Im not being difficult Im just asking its like years ago its impossible Im sorry So your testimony is you dont recall flying on that flight with Virginia Roberts Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I cannot testify to that flight Lets look at the next flight which is on the from the Virgin Islands back to Palm Beach JE Jeffrey Epstein Ghislaine Maxwell Virginia Roberts the same individuals on the above flight A It doesnt say my name it has some initials I understand the initials GM Do you recall flying on a plane on one of Jeffreys planes from the Virgin Islands to Palm Beach with Virginia Roberts A I do not Was there any other person that flew with Jeffrey Epstein with frequency during that time period in these logs that have the initials GM MR PAGLIUCA Objection to the form and foundation A I would have to look at all the flight logs I have no idea I flew frequently Why dont you take a look at the next three pages and see if that refreshes Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential your recollection MR PAGLIUCA You are talking about MS McCAWLEY She can pick any couple of pages those have a lot of the individuals on them so that is a good sampling MR PAGLIUCA So pick any pages you want Does that refresh your recollection at all as to whether GM represents you or some other individual A Again I cant testify whether that represents me or not I dont see any other GMs but you have to understand that even if my name is on that record doesnt mean I was on the flight So are you contesting the accuracy of the flight logs In other words you said it doesnt represent you are on the flight so is it your testimony just because a name is listed doesnt mean they were actually on the flight MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I cant testify to what these are records that were produced by is on here so these arent federally mandated records so I cant testify to what he produced I would like you to turn to page at the bottom the Bates number is And the month is A Okay If you go down to the number that is that would be youre going to see on that line an which is a and then you will see which is going to be Im going to pronounce it incorrectly Im sure Im not pronouncing that correctly Then you will see in the list you will see JE GM it looks like A I believe it says male Yes Then I believe Is that GM on this page representative of you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Well this would be a flight that I would potentially remember with on it but I dont actually recall going to Russia Are those your initials do you recall being on the flight A Those are my initials with I dont recall this flight either but I would be more likely to if I had a bit more time to study the timing of this Your testimony is you dont recall flying with from to A I dont recall the to flight I have definitely flown with On that same page you will see beneath there beneath you will see the indication same as above same as above same as above in the column that originally had the initials A Uh-huh And the names Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Uh-huh Do you recall flying with from to A I do So the GM that would be represented in that column would be you A I recall going to with so that is likely to be me You were on Jeffreys plane for that trip A I believe I was Do you know who is A I do not Im going back towards the front which is going to be please And youre going to see A Hang on Im not Take your time A Okay You are going to see in the date column you will see and then about halfway down you will see Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential then you will see the which is the column which is where I want you to start looking at the log and there youre going to see A Okay If you look at the column if you go back up to the top on the if you look at the column you will see JE GM Virginia Roberts and I believe it says sorry Im not reading that very well Do you recall flying from if you see the dates the Do you recall a trip that went from the United States to and to the places I just mentioned where Virginia Roberts was on the plane with you MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of I I I I MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I already testified that I dont recall Virginia on any of these flights I would like to mark as Maxwell I will put it at the top Maxwell Exhibit photo marked for identification MR PAGLIUCA Has this document been produced in discovery MS McCAWLEY Yes MR PAGLIUCA Do you have a Bates number MS McCAWLEY This one doesnt Im going to ask you MR PAGLIUCA I dont recall seeing this document so I would like to see a Bates number document before we ask questions about it MS McCAWLEY Can you go look for it and I will continue We will set that aside until we get a Bates number You may want to leave that log up and set it to the side and we will bounce back to that Do you recall I think earlier Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential you said you visited Jeffreys island I think they called it St Jeffrey or St James the U.S Virgin Island home A St James Do you recall whether was ever on that island A Categorically definitively absolutely without a shadow of a doubt when I was present or any other time that I am aware of was ever on that island I do not believe he went to that island ever ever that is an absolute fabrication and an absolute flat out lie Was ever at any of Jeffrey Epsteins homes when you present other than the island I know you said that did not happen the home in either New York or Palm Beach or New Mexico A I do not believe at any time was at any of Jeffreys homes I have absolutely no knowledge or otherwise that he was ever there You dont recall having dinner with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential him at any of those homes A Again Virginia is absolutely totally lying This is a subject of defamation about Virginia and the lies she has told and one of lies she told was that President Clinton was on the island where I was present Absolutely percent that is a flat out total fabrication and lie You did fly on planes Jeffrey Epsteins planes with President Clinton is that correct A I have flown yes Would it be fair to say that President Clinton and Jeffrey are friends A I wouldnt be able to characterize it like that no Are they acquaintances A I wouldnt categorize it He just allowed him to use his plane A I couldnt categorize Jeffreys relationship When you were on the plane with Jeffrey and President Clinton did you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential observe Jeffrey and talking A Im sure they did Did they seem friendly A I dont recollect Was Epstein one of the original people that conceived the MR PAGLIUCA Objection to the form and foundation Do you know A I dont have I dont know what you are talking about You dont know what Im talking about Did you ever not at one of houses but did you ever eat dinner with and Jeffrey Epstein A Are you just talking in general anywhere In general A I believe on a plane of this nature we would have had a meal But not outside of the travel on Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential the flights A I cant recollect having a meal with them but just so we are clear the allegations that had a meal on Jeffreys island is percent false But he may have had a meal on Jeffreys plane A Im sure he had a meal on Jeffreys plane You do know how many times he flew on Jeffreys plane A I dont Do you know who is A I do How do you know him A He used to work or still works for Did you ever have a relationship with him A We are talking about adult consensual relationships its off the record Im not asking what you did with him Im asking if you ever had a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential relationship with him MR PAGLIUCA If you understand the term relationship certainly you can answer that A Define relationship Somebody that you would have spent time together either seeing them in a romantic relationship or A You need to be what do you mean by romantic I was friends with but you are suggesting something more so I want to be clear what you are actually asking me You defined it You said you were friends with him If thats what you were thats all I need to know While you were on the trip with do you recall where you stayed at these locations in other words would you leave the jet and stay overnight at a hotel do you have a recollection of this trip A I recollect the trip but if youre asking me where we stayed you can see its a very fast paced trip It was very tiring and Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential I dont recollect where we stayed Do you recollect if you stayed at the same place stayed In other words if you left the plane to go a hotel did you all go together is your recollection A I honestly dont recollect no Part of this trip we were just talking about there is a flight that goes to Thailand do you remember being in Thailand MR PAGLIUCA Objection to the form and foundation A Are you asking me On the trip A Are you referencing something The part that let me make sure Ive got it here The entry that would be the Thailand would be the one let me make sure Im correct I have you on the wrong page its actually the page before Its going to be And its going to be the entry on starting on and then it goes down to where it has the same as above to Im saying Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Thats what the document says Im not representing the date but there it is So the last leg of that where it says same as above has the second to last Im sorry on the Do you remember being in Thailand with A I do Do you remember what the purpose of that trip was A I dont Do you know whether do you recall did you stay the night in Thailand A I dont recall Do you recall why you went to Thailand A I dont recall Who is A She I believe was a stewardess on this flight Did she perform any massages on the Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential flight A I dont recollect any massages on the flight Do you know who is A It doesnt no I dont know who that is I cant recall This is not in color its a black and white but it has the Bates label on it Should I take the sticker off the one that has I dont know if you want to swap it MR PAGLIUCA Let the record reflect I am replacing this on the black and white copy of this exhibit with So we were talking earlier we were looking at the flight logs and we were talking about a trip and let me just get you back to the page Case Document Filed Page of MAGNA9 EG A ER ICES Page Maxwell Confidential Can I direct your attention to the picture please A Of course Can you tell me who is in this picture who is pictured here and for the court reporters benefit can you go from the left of the picture to the right of the picture to the extent you can identify the individuals A Sure I cannot identify the person on the left I cannot identify the person next left I can identify Jeffrey Epstein I cannot identify the next person to his right and the next person in the picture is myself Is the individual all the way to the left at the beginning of the picture does that resemble You might want to look at the color version if that helps you at all I know its not the marked one I dont if thats easier to see they are both dark A That does not look like at all Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you recall MR PAGLIUCA Lets mark this then as deposition Exhibit since we are referring to it and then you can give us copies as well MS MENNINGER Its different because it has other people in this color photo Maxwell Exhibit photo marked for identification Do you recall who took this photograph A I do not Do you recall this photograph being taken by Virginia A First of all I dont know where we are So you dont recognize the building A I dont recognize the building and I dont recognize the only two people I recognize in the picture are Jeffrey and myself Does this like look a picture of a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential building that you would have seen when you were on the trip in Europe MR PAGLIUCA Objection to the form and foundation A I cant possibly answer that Do you recall Virginia ever taking pictures A I barely recall Virginia period Do you recall her ever taking pictures A No I dont Im going to direct your attention still within the flight logs to starting on the next page from where you just were which is going to be And the date at the top says you will see and Im directing your attention down towards the middle to the bottom where you will see the numbers A Uh-huh And weve got actually Im going to direct your attention to the one that starts with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and in the line the remarks line you will see JE GM MR PAGLIUCA Are you reading the 29th is that what youre reading MS McCAWLEY Im reading the 29th yes Below that you will see JE GM Do you see that A I do Do you recall a trip from Teterboro to Santa Fe and Santa Fe back to Palm Beach with these individuals A I dont Do you recall being on a plane with and Virginia Roberts A I dont Do you recall ever witnessing any sexual interaction on one of Jeffreys planes with any of these individuals A I do not absolutely not Did Jeffrey have a fold out bed on Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential one of his planes A There was a bed on one of his planes that folded out yes Do you recall whether with respect to this being in Santa Fe do you recall whether you were there for some form of a party MR PAGLIUCA Objection to the form and foundation A I dont recall the trip at all and this looks like a total work trip not a party trip What would be the difference between a work trip and a party trip A Just that I would be on trips for work and I believe that this looks like looks like its one of the probably one of the designers and the time would meet with a trip to decorate the house just the timing of it So would Virginia be brought on trips that were for the purpose of work and decorating the house A Like I said I never worked with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential her but you would have to ask Jeffrey what he brought her on the trip for But she would travel with him when there was a work trip like this A I cant Im seeing that she is on this flight but I have no idea what she is doing he invited her it would not be my job What about Nadia Bjorlin would she regularly travel with Jeffrey on flights A I have no idea you would have to look through the flight logs I have no idea Your recollection is what is your recollection do you recollect Nadia traveling often on flights with Jeffrey A Absolutely not No not at all I dont recollect her actually on the flight at all I think you can set that aside for the moment Maxwell Exhibit message pad pages marked for identification We will mark as Exhibit these Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential excerpts from we will identify what they are but from the message pads Did you want to correct anything A I want to make an addendum Would you mind rereading the last question back to me Record read A I also just want to say that at this point I cannot recollect flying to parties Jeffrey went for work so was this in Santa Fe this flight as well The flight we were looking at yes but it was to Santa Fe A I dont recall going to any parties in Santa Fe at any time but certainly flying to Santa Fe for a party seems highly improbable So Im going to direct your attention to the document that I set before you which is Bates number and it has different Bates numbers because its a smaller version of the larger production These are the pages I will be asking about In the time that you were working Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential with Jeffrey in Palm Beach do you recall a process for taking anybody at the house taking messages when incoming phone calls came in A You are supposed to take a message and receive the message and write the message down Who was the message was for what time it was taken and who took it and what the message was obviously Does whats in front of you look familiar with respect to the message pads that you would have used at the house A It is familiar Im going to direct your attention to the second page of it MR PAGLIUCA These all have SAO numbers on them or Bates ranges and I dont see any of your Bates ranges on these I know you have produced message pads but those have your Bates range numbers on them and Im wondering if these are different documents MS McCAWLEY Its the same just ours have the Bates underneath them Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential These were produced as part of the rule discovery We can get the additional Bates if you want The one Im asking about first is the You can look at that and then I will identify the Bates number referenced in this case I want to direct your attention to the top right-hand corner just so I have an understanding of how these messages were taken So I see that it says at the top it says in the for line it says Ms Maxwell and the date of and then I see under the line it looks like or something like that a phone number and a message saying returning your call and on the bottom it looks like Explain to me is this does this represent taking down a message for you from is that how these work MR PAGLIUCA Objection to the form and foundation Go ahead My question is Im trying to understand how the messages were taken Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Looking at this message pad where it says signed can you tell me who was A I cannot You do not know Typically when these messages were taken in your practice when you were there would the individual who took the message write their name on the message MR PAGLIUCA Objection to the form and foundation A I dont recollect you can ask who wrote it so you can find out who it was Do you know who is A I dont Im going to direct your attention do we have a Bates number for that MR EDWARDS Giuffre for that one I will direct your attention to the first page which has the on it A Okay Now at the top of that document on the right-hand side the message that reads Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential for JE date message and then its signed GM Is that your signature A Thats not my handwriting Would other people take a message how did this process work is there someone else in the house with the initials GM MR PAGLIUCA Objection to the form and foundation A I cannot answer that Its not my handwriting Im trying to understand how this gets there If you took a message and didnt write it down would someone else record that message for you MR PAGLIUCA Objection to the form and foundation A All I can tell you this is not my handwriting so I cannot I have no idea what that is Was the practice that what was the practice when someone answered the phone with these message pads what were they supposed to do Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A They were supposed to take a message and the time and date and give the message Were they supposed to indicate who took the message A They were but it wasnt I dont really recall the actual process I can see from here it looks like you were supposed to but thats not my handwriting so I cant say what that was Do you know who is A No I dont Do you know whether was under the age of A I just testified I couldnt remember who she was so it would be difficult to know how old she was Do you know if she was coming to the house to provide massages A I dont remember who she is at all so no And then I would like to direct your attention to the message right underneath it Which says JE Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and has a phone number and the message says wants to know if she should bring her friend tonight What is that message referring to MR PAGLIUCA Objection to the form and foundation A I cant possibly know Did individuals at the house take messages for underage girls to come over and bring friends for the purpose of providing massages MR PAGLIUCA Objection to the form and foundation A How would I possibly know what you are talking about Did you record messages at the house A Its not my job You did from time to time record messages A Hardly ever But you did from time to time do it A Im just saying I hardly ever took Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential messages very very very very infrequently Do you know if brought her friend over on that night MR PAGLIUCA Objection to the form and foundation A One I dont know what this message is I dont know if I was in Palm Beach I dont know who is I dont know who is and I dont know what this message is referring to So on January 2nd of were you in Palm Beach A I dont know Where would you have been other than Palm Beach at the time A I could have been anywhere Where did you typically live A What are you asking me So for example in where was your primary residence was it wherever Jeffrey was living and staying or was it independent of that A What was the date again Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential In A The end of January the beginning A I dont know I could have been anywhere Jeffrey and I were leading almost separate lives by then If you were at the house that day did you recall seeing anybody by the name of MR PAGLIUCA Objection to the form and foundation A I dont know if I was at the house so I cant testify to that Lets flip back to the next page the one we were on before the the message towards the bottom that says for Jeffrey message of Ghislaine And it says Would it be helpful to have and then redacted come to Palm Beach today to stay here and help train new staff with Ghislaine Who were you referring to in that message do you remember MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential The question is do you recall this message A I do not recall this message Do you recall training a female under the age of at Jeffreys home MR PAGLIUCA Objection to the form and foundation A I never trained a female under the age of at Jeffreys home Did you ever say it would be helpful to have a female under the age of come to Palm Beach today to stay here and help train new staff with Ghislaine A I never asked anyone under the age of come to help train new staff Im going to flip to the next page which is A By the way that is not my handwriting and its not dated and I couldnt possibly tell you who that is Did you hear that You got your testimony on the record Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Yes MR EDWARDS Giuffre Im going to direct your attention to the top right-hand corner for Mr Epstein message a phone number and called Do you know who is A I dont Do you know that was at the time she left this message MR PAGLIUCA Objection to the form and foundation A I dont know who is And then Im going to direct your attention to the bottom left which is a message JE message of and the message says He just did a good one years she spoke to me and said I love Jeffrey Was referring to sex with an year old in that message MR PAGLIUCA Objection to the form and foundation A How could I know what is Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential referring to Do you know if had sex with an year old that he referenced to Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A How could I possibly know Did Jeffrey Epstein or ever tell you that had sex with an year old MR PAGLIUCA Objection to the form and foundation A I have no idea what you are talking about Did they ever tell you that A I have no recollection of ever hearing such a ridiculous thing I will turn to the next page which is SAO MS MENNINGER Do you have the Bates number The bottom right-hand corner Mr Epstein the date Ms Maxwell it says it says quote is Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential available on Tuesday no one for tomorrow Is this a message you took A Its not my handwriting and I dont know who is So when it says Ms Maxwell in the line there is that you calling for Mr Epstein MR PAGLIUCA Objection to the form and foundation A I didnt write it I dont know when this message was taken I dont even know what its referring to and I dont know what my name is doing on that message pad I know you said you only took them a few times Do you have a recollection of taking messages of females who would call the house to indicate whether or not they were coming over MR PAGLIUCA Objection to the form and foundation A Give me a date range On A How would I know if Im in Palm Beach most likely not Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im asking if you have a recollection of taking messages for girls who would call the house A Girls Females who would call the house A Over the age of is A I dont know who is so I cant testify anything to Your name is on the message A I didnt put it there and I dont know what its doing there So your testimony is you didnt take this message A I obviously didnt take the message its signed by somebody its not my handwriting We dont know if Im in Palm Beach Did you arrange for to have his friend come over on Tuesday of this week A I dont know who is so it would be hard for me to arrange anything with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential someone I dont know Why is your name reflected on this message pad MR PAGLIUCA Objection to the form and foundation A I have no idea You would have to ask whoever took the message Did you in the course of your work regularly take messages for Jeffrey Epstein A I already testified I hardly ever did Would you in the course of your work regularly set up appointments for females to come over and give massages for Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A Can you specify females you mean adults over the age of Did you regularly set up for Jeffery adults over the age of to come for massages A I didnt regularly do that no Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Would you take messages with respect to females over the age of to come over for a massage A I already testified I hardly ever did take messages But would you A I already testified I hardly ever I know hardly ever but did you A Over the course of time it is possible I may have taken a couple I have no recollection I hardly ever did and I did so irregularly that it would hard for me to pinpoint Did you ever take a message for a female under the age of to come over for a massage or for any other reason to be with Jeffrey Epstein MR PAGLIUCA Object to the form and foundation A I hardly ever took a message I have absolutely no way of knowing maybe one of my friends daughters called to say they were coming to visit me I have never taken Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential messages I dont know about how I would possibly know if somebody I spoke to one or two times I took a message is how old they would be but I have never taken a message where I was aware of anything being under the age of and I probably took it so infrequently it would be impossible Can you turn to it should be the next page A Uh-huh Do you see at the top it says for Mr and then the name is redacted It says I have a female for him Why would a minor be calling Jeffrey to say they have a female for him Do you know MR PAGLIUCA Objection to the form and foundation A First of all I dont know thats a minor I dont know who took the message I will represent to you these are police reports and minors names have to be redacted for privacy purposes MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation Do you know why a minor child would be calling Jeffrey and leaving a message to say quote I have a female for him MR PAGLIUCA Objection to the form and foundation A I cant testify anything about this message I dont know anything about it Im going to direct your attention to the next page If you look at the bottom left you are going to see a message for Jeffrey from it says she doesnt have a number and left a message that she called Do you know who is A I do not Do you know that was at the time she placed this call to Jeffrey A I dont know who is Would Jeffrey regularly have year olds call and leave messages MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A How would I possibly these were messages taken when I was not at the house and I have no idea who they are nor how old they are nor anything How do you know you werent at the house on this day A I was hardly at the house in So you could have been there you just dont know A In the five days I might have been there in I suppose its possible but its unlikely MR PAGLIUCA Do you know why this isnt redacted if you are representing all the names of people who are underage have been redacted from these records MS McCAWLEY I think it was my assumption is it was a miss by the police department I will direct your attention to so you will skip a page and go back its the final page in the message pads and you will see on the top left for Jeffrey on from with a phone Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential number It says quote He has a teacher for you to teach you how to speak Russian She is two times eight years old Not blond Lessons are free and you can have your first today if you call Do you know whether sent a Russian girl that was years old over to Jeffrey Epsteins home MR PAGLIUCA Objection to the form and foundation A I do not know Did you ever observe a Russian girl that was years old come to Jeffrey Epsteins home A I am not aware of any year old Russian girl that I can recall in Jeffrey Epsteins home Do you know whether Jeffrey Epstein had sex with a year old Russian girl MR PAGLIUCA Objection to the form and foundation A I do not know THE VIDEOGRAPHER Its This will be the end of disk we are Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential off the record Recess A I Time noted p.m I A I A resumed and testified as follows EXAMINATION BY Contd MS McCAWLEY THE VIDEOGRAPHER Its now were starting disk No We are back on the record Ms Maxwell before the break we were talking about and I think its one of the exhibits thats marked in front of you Im not sure of the number but the police report that I showed you earlier today Now that you have knowledge of the police report and the criminal investigation with respect to Jeffrey Epstein do you believe that Jeffrey Epstein abused any minor children MR PAGLIUCA Objection to the form and foundation A Can you repeat the question please Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and break it down so its more understandable Now that you have the police report that I showed you this morning that you had an opportunity to look at A You gave it to me I did not look at it The questions that I asked you about the police report you are aware there is a police report A I am aware there is a police report You are aware there was a criminal investigation of Jeffrey Epstein A I am aware that there was that Now that you are aware of those two things and having talked to Jeffrey Epstein do you believe Jeffrey Epstein sexually abused minors MR PAGLIUCA Objection to the form and foundation A Can you reask the second part of that question please Sure The two documents we were Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential talking about the document and the investigation you said you are aware of and after having talked to Jeffrey Epstein do you believe Jeffrey Epstein sexually abused minors MR PAGLIUCA Objection to the form and foundation A What do you mean I talked to Jeffrey you need to break the question down further So you have the police report A I do And you are aware of the criminal investigation A I am Lets take those two things After knowing those two things do you believe that Jeffrey Epstein abused minor children MR PAGLIUCA Objection to the form and foundation A Can you explain what you mean by the question actually I think the question speaks for itself I will try again I will say it one Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential more time because I want you to be able to understand it Knowing that you have the police report here and knowing about the criminal investigation do you believe that Jeffrey Epstein sexually abused minors MR PAGLIUCA Same objection A I know what you put in front of me and I know what I read Im asking what you believe do you believe Jeffrey Epstein sexually abused minors A I can only tell you what I read and what you showed me Im asking what you believe from your own belief do you believe that Jeffrey Epstein abused minors A I can only go from what I know personally and what I know personally about what Virginias lies talked about She is the only person I know that actually claimed that And I can say with certitude that everything Virginia said was a lie You are aware Jeffrey Epstein was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential sentenced for sexual abuse are you aware of that MR PAGLIUCA Objection to the form and foundation Are you aware that Jeffrey Epstein served time for sexual abuse of a minor MR PAGLIUCA Objection to the form and foundation A I dont believe thats what he was sentenced for actually So you dont know that Jeffrey Epstein served time for sexually abusing a minor MR PAGLIUCA Objection to the form and foundation A I dont believe thats what he was sentenced for Do you know that Jeffrey Epstein was convicted for procuring a minor for prostitution MR PAGLIUCA Objection to the form and foundation A I dont know exactly what he was convicted of I dont know that he was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential convicted I know he spent time in jail Do you know that he spent time in jail related to an issue with a minor child MR PAGLIUCA Objection to the form and foundation A I did not know that What did you think he was spending time in jail for A I only know he went to jail for it was alleged that he hired had an underage prostitute So knowing that do you believe that Jeffrey Epstein sexually abused minors MR PAGLIUCA Objection to the form and foundation A I can only tell you what he went to jail for Im asking what you believe Im not asking what he went to jail for Im asking for your belief A I cannot testify to what I believe I can only say what I have seen in the reports and I know he went to jail You can testify to what you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential believe Do you believe A I can only testify Let me finish the question so the record is clear Do you believe Jeffrey Epstein sexually abused minors MR PAGLIUCA Objection to the form and foundation You can answer A I can only testify to what I know I know that Virginia is a liar and I know what she testified is a lie So I can only testify to what I know to be a falsehood and half those falsehoods are enormous and so I can only categorically deny everything she has said and that is the only thing I can talk about because I have no knowledge of anything else Im not asking about Virginia Im asking whether you believe that Jeffrey Epstein sexually abused minors A Again I repeat I can only go on what I know and what I know is a falsehood based on what Virginia said Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you believe Jeffrey Epstein sexually abused minors A Again I repeat Virginia is a liar and based on Virginias stories that is what she lied and I can only then talk about what youve showed me in the police reports and I know he went to jail Do you believe that Jeffrey Epstein sexually abused minors Im asking about your belief A Again I just repeat I can only go my belief is Virginia is a liar What is that belief A She is an absolute liar and everything she said is a lie and therefore everything that stems from that is a lie So do you believe that Jeffrey Epstein sexually abused minors A Again can we move on from here No You are going to answer the question A I have already No you havent A I have Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you believe Jeffrey Epstein sexually abused minors A Again I repeat the only person I know who has talked about these things that I have personal was personally present was Virginia and I can only talk to Virginia and she is a liar Setting aside Virginia Take her out of the picture Its my question A We are here today because of Virginia and her lies because this is a defamation suit Setting aside Virginia do you believe Jeffrey Epstein sexually abused minors A I cannot set aside Virginia because thats why we are here and this is the only reason I am sitting here in this room and I will not set her aside and I cannot comment about anything else except her because she is the only person I actually know about Are you refusing to answer that question A I am not refusing the question I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential can only testify about Virginia who is an absolute total liar and you all know she is She lied about her age you know she lied about absolutely everything So I can only go on what I know as a liar and she is a liar an exaggerator a fantasist and absolutely true terrible person I want you to listen very carefully I am asking you to set aside Virginia A I cant set aside Virginia I am asking you to do that for purposes of this question MR PAGLIUCA She doesnt have to MS McCAWLEY She can refuse to answer the question A Im not refusing to answer the question You are refusing My question has nothing to do with Virginia Let me make the record here My question has nothing to do with Virginia I want it to be clear for the court My question has nothing to do with Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential What Im asking you is whether you believe Jeffrey Epstein abused minors MR PAGLIUCA I object to the form and you made your record she answered the question A fair reading of her answer is she doesnt have a belief because she doesnt have any personal knowledge MS McCAWLEY Now you are testifying for the witness Let her answer the question MR PAGLIUCA Its a fair answer to the question A Again I testified my only personal knowledge concerns Virginia and everything Virginia has said is an absolute lie which is why we are here in this room If you are asking me to testify about things I have no knowledge of other than the police report that you showed me I am not in a position to make a statement based on that because you are asking me to speculate and I cannot speculate Im asking you about your belief Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im not asking you to speculate at all Im asking what you believe A You are asking me to speculate and I wont speculate Im not asking you to speculate Im asking what you believe MR PAGLIUCA She answered the question and we can move on MS McCAWLEY She hasnt answered the question MR PAGLIUCA We are not going to engage in this debate She answered the question If you want to mark it and move to compel an answer to the question have at it Okay Ms Maxwell is it your belief that Jeffrey Epstein interacted sexually with minors A Again you are asking me the same type of question exactly but with different language Again my only knowledge of somebody who claims these things that I have personal knowledge of is Virginia Virginia is an absolute liar and everything she has Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential said is a lie Therefore based on those lies I cannot speculate on what anybody else did or didnt do because if Virginia is the example of what that story is and everything she said is false so everything that leads from that is false So the other minor children in the police report are also telling lies about being sexually abused during massages with Mr Epstein MR PAGLIUCA Objection to the form and foundation Counsel can you show me in these police reports who the minors are MS McCAWLEY Im asking my question MR PAGLIUCA You are making a representation about numbers you are making a representation on the record about what people said or didnt say We have no knowledge about that These are all redacted records so these are bad questions They dont lead to any admissible evidence It is only being Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential propounded to the witness to harass her So we are done with these questions MS McCAWLEY Are you done MR PAGLIUCA Yes My question is are you aware that Jeffrey Epstein was convicted of having relations with a minor child MR PAGLIUCA She answered that question already MS McCAWLEY Im getting to my next question MR PAGLIUCA Ask your next question Dont keep asking the same question MS McCAWLEY You are now shouting I want the record to reflect that you are interrupting the deposition I ask you to calm down take a deep breath and please let me ask my questions MR PAGLIUCA Your behavior is inappropriate I will ask you again Do you believe that Jeffrey Epstein Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential interacted sexually with minors A Again I go back to this my only actual knowledge is with Virginia and Virginia is a liar so I can only talk to what Virginias story and as I said before and there are so many examples I mean thousands of examples of her lies that that is the only thing I can talk to Based on that you do not believe that Jeffrey Epstein sexually abused minors A Again as I said Im only talking to what I know I can only talk to Virginia So is it your belief that Jeffrey Epstein did not sexually abuse minors A Again I can only talk to what I know and I know that Virginia is a liar and that what she said is a lie So I can only testify to what she accused and you guys put in the press for salacious purposes and whatever terrible inappropriate unethical and terrible reasons you chose to do that about me and I can testify those are all lies Do you know whether Jeffrey Epstein Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential sexually abused any minor children A Again I only know percent that Virginia is a liar I can only talk to Virginia her lies and your inappropriate unethical really unattractive terrible use of her and the way that you have abused the system used the press for purposes that are unethical inappropriate and appalling Do you believe that Jeffrey Epstein used massages to lure minors to have sex with him A Again that is Virginias testimony which is a lie But do you believe that A Again I refer back to Virginia Im asking whether you believe it or not A I can only go with what I know and I know Virginia is a liar and therefore thats a lie So you dont believe that A I said I only know that Virginia is lying Are you aware that Jeffrey Epstein Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential is a registered sex offender A I am Are you aware that Jeffrey Epstein paid considerable amounts of money to settle lawsuits with the minor children that he had sexual contact with MR PAGLIUCA Objection to the form and foundation A I have no knowledge of those issues Why did you continue to maintain contact with Jeffrey Epstein after he pled guilty A Im a very loyal person and Jeffrey was very good to me when my father passed away and I believe that you need to be a good friend in peoples hour of need and I felt that it was a very thoughtful nice thing for me to do to help in very limited fashion which was helping if he had any issue with his homes in terms of the staffing issues It was very very minor but I felt it was thoughtful in somebodys hour of need Did he continue to pay you during Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that time period A I was paid a little You were paid A Yes When you say a little what you did mean by that A I dont recall exactly the amount So in when you left him what were you being paid A I just told you I dont recall Were you being paid A I just dont you I dont recall Were you paid over a million dollars A I think I would remember over a million dollars So it was under a million dollars A It was under a million dollars Was it over A I just told you it was under it was an amount of money less than less than a million dollars and I did it out of thoughtfulness and consideration for somebody who was in trouble Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you have an attorney to consult with during the criminal investigation of Jeffrey Epstein A I dont believe I did When did you learn that a search warrant was executed for the Palm Beach house A I dont recall exactly Were you present at the house in advance of the search warrant being executed MR PAGLIUCA Object to the form of the question A I dont remember when the search warrant was executed and I dont remember the year that the search warrant was executed and whenever that was I already testified I was very very infrequently at the house So highly unlikely but I was there a couple of days I just dont know which days it was in relation to the police situation Did you have a computer at the Palm Beach home that was a computer that you would use A No Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Was there a computer available for use in the Palm Beach house A Can you be more specific Was there anywhere in the Palm Beach house where there was a computer where you said you worked for him and there were other staff in the house was there ever a computer in the Palm Beach mansion that was accessible by you or other staff MR PAGLIUCA Objection to the form and foundation A I stopped being regularly at the house sometime in so from to when the police search was executed I have no memory of what there was or what there was not I can only testify for what was there when I was present largely So in when you were still there was there a computer that was accessible to you or other staff at the house MR PAGLIUCA Objection to the form and foundation A There was a desktop computer that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential people could use just like you would use if you needed to go online to get something that people could use Was that on a desk that you would use in your work capacity when you were at the house A It was a desk it was a room I was I didnt really use that computer Were there images of naked girls whether they be under the age of or over the age of on that computer A I have no recollection of any naked people on that computer when I was there in we are talking What about from say to A No I cant recollect any naked pictures Why were the computers removed from the house before the search warrant was executed MR PAGLIUCA Objection to the form and foundation A I have no knowledge of anything like that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you know where the computers are now MR PAGLIUCA Objection to the form and foundation A I dont know what computers you are talking of and I have no idea what you are referencing In you said there was a computer in a room on a desk A Right Do you know where that computer is now A I do not Did you take pictures of nude females in any of Epsteins homes or in and around the homes out by the pool or anywhere like in the Palm Beach home the New York home USVI home or the New Mexico home MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Did you take pictures of nude woman over or under females in any of Jeffrey Epsteins homes inside or outside in Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential or around the home A I think we need to distinguish between anyone under the age of and over the age of We will start with did you take pictures of nude females in or around any of Jeffreys homes of women or females that were under the age of A No Did you take pictures of nude females A Nude you mean with no clothing on Or half nude with no top on any sort of nakedness to an individual In any of Jeffreys homes either Palm Beach New Mexico USVI or New York either outside by the pool anywhere in or around those homes of females over the age of A So it is possible that I took pictures of people that were somehow semi or had some clothing on or no clothes on but at no time were any of these pictures remotely inappropriate They were you could see them Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential in a mainstream magazine today there would be no inappropriateness they would be covered concealed you wouldnt see anything at all The types of first I took very few and they were always by request this was a picture you could put on your gift to your parent or to your grandparents to put on their mantel piece It would be a very benign sort of attractive picture where you wouldnt see anything Who would request those pictures A From time to time people men and women would ask to have nice photographs of them taken And did Jeffrey Epstein request those pictures A I dont ever recall him asking me to take pictures Did you give him pictures of naked females as a present A I dont recall ever giving a present of I dont know why a photograph would constitute a gift Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Not as a gift Do you recall ever giving Jeffrey Epstein pictures that youve taken of these individuals in a naked state MR PAGLIUCA Objection to the form and foundation A First of all weve already established that they are not naked state photographs A piece of them being naked as you described A I said they would be attractive as you would see in mainstream magazines and those pictures could be a picture of a hand or a foot they didnt necessarily constitute I know where you are headed with this and its nowhere appropriate and its really unattractive Im not headed anywhere Im just asking the questions Did you give Jeffrey Epstein any of these pictures that you took of females in the state that you described A I cant recall ever giving him pictures but it is possible that I took Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential pictures of people that would end up or a friend of his that he would have not naked or not inappropriate in any way that he might have somewhere in his house Name for me all the individuals who you took these pictures of A Its entirely impossible for me to name people First of all it was just it would not be possible I took thousands of photos not of people I mostly take pictures of landscapes and things I have no recollection specifically of people that I took pictures of So you cant remember is it your testimony you cant remember one person that you took a picture of in either a naked or semi naked state A I seriously cannot recall I just dont recall Did you take a picture of Virginia Roberts either alone or with another individual in a naked state A I have never taken I believe any pictures of two people in any type of Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential situation naked as you describe Did you take a picture of Virginia Roberts on her own without another individual in it in a naked state A I dont recall ever taking a picture of Virginia naked we are not referring to someone with no clothing on at all we are referring to someone that could be semi clad or could have a towel or we are not referring to anything inappropriate Was this a hobby of yours to take pictures of the type that you are describing MR PAGLIUCA Object to the form A I just testified I didnt take pictures of many people My preference is pictures for landscapes and for architectural pieces Where are those pictures today A I have no idea Do you have them in your home A I do not Do you have them on your computer A I do not What has Jeffrey Epstein told you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential about the allegations related to the criminal investigation that he was involved in A I really cant say not because I dont want to say but I just think of what he has said to me over the course of this time Did he explain it to you and explain what the charges were against him A I never had a detailed conversation with him as I recall Not detailed just did he explain anything that was happening to him A I havent spoken to him for so long I cant possibly testify to what conversations I had with him over the course of time Did he talk to you about any of the girls that were making allegations against him other than Virginia MR PAGLIUCA Objection to the form and foundation A You are talking about the police records again all of that Yes A I have never had a conversation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential about those things What has Jeffrey Epstein told you about Virginia Roberts A That she is a liar What does he base that on MR PAGLIUCA Objection to the form and foundation A You would have to check with him I can tell you why I think she is a liar Im happy to do that Did he tell you he did not have sexual relations with Virginia Roberts A I can only testify what I know Im asking has he told you that he did not have sexual relations with Virginia Roberts A I can only tell you what I know about Virginia Roberts I cannot tell you what he knows about Virginia Roberts Im asking did he tell you that he did not have sexual relations with Virginia Roberts A All he told me is she is a liar Thats all he said about Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Roberts A We went through all the lies that you have sold to the papers and sold in general and we have analyzed her lies and your lies and your inappropriate behavior in detail Did he ever say that he did not have sexual relations with Virginia Roberts A I just testified that we went through all of her lies I understand what you said Im asking you a question Did he ever tell you that he never had sex with Virginia Roberts A I dont recall whether he ever I dont know I ever had that question We focused on the lies she did say she had with him as relates to me I dont remember asking him about his problems with her Im interested in what she says about myself Did you also talk about what things that Virginia Roberts was saying that were true A There isnt anything that she said Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that was true Nothing she said that you are aware of is true A I think she is correct when she talks about what her name is Anything else A Im sure there must be one or two other details but they are so far and few between I would have to look in detail at all of her allegations to pinpoint what possibly could be true Did you ever ask Jeffrey if he had sex with minors A I have never been asked that question You never asked him that question What analysis did Jeffrey do to determine that the statements Virginia Roberts were making were lies MR PAGLIUCA Objection to the form and foundation A Ask me again please What analysis did Jeffrey do to determine that the statements that Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Roberts were making were lies MR PAGLIUCA Objection to the form and foundation And to the extent that any of this answer calls for any privileged communication Im instructing with myself or another lawyer representing you or in any common interest agreement Im instructing you not to answer MS McCAWLEY The court ruled she is entitled and you had to produce documents about communications with Jeffrey thats what Im asking about Im not asking about communications with lawyers Im asking what analysis did Jeffrey do to determine that the statements that Virginia Roberts was making were lies if you know MR PAGLIUCA My objection is to the extent she learned any of that information as a result of either a privileged communication from a lawyer one of her lawyers or a privileged Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential communications subject to a joint defense agreement or common interest agreement Im telling her not to answer To the extent she has information outside of those things she is permitted to answer Do you understand So if it was a conversation with a lawyer which Im not asking about I dont want you to tell me about your conversations with lawyers I want you to tell me whether Jeffrey Epstein ever told you what he analyzed in order to determine which of of what Virginia were saying were lies A I do not know what he did no So you agree she is lying Singrid I do not agree with that and Im asking the questions A You just said her lies Im repeating a statement you made Are you saying its an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential underage A I can only testify to what I saw and what I was present for so if you are asking me what I saw then I am happy to testify I cannot testify to what somebody else did or didnt do Did you issue a statement in stating that Virginia Roberts claims were quote obvious lies MR PAGLIUCA Objection to the form and foundation You can answer A You need to reask me the question Sure Did you issue a press statement in January of stating that Virginia Roberts claims were quote obvious lies MR PAGLIUCA Objection to the form and foundation A Can you ask it a different way please I will ask it again and you can Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential listen carefully Did you issue a press statement in January of where you stated that Virginia Roberts claims were quote obvious lies MR PAGLIUCA Objection to the form and foundation A So my lawyer instructed to issue a statement Today did you say that Virginia lied about quote absolutely everything A I said that there are some things she may not have lied about So are you saying its an obvious lie that Jeffrey Epstein engaged in sexual contact with Virginia while Virginia was underage MR PAGLIUCA Objection to the form and foundation A Can you ask the question again please Are you saying its an obvious lie that Jeffrey Epstein engaged in sexual Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential conduct with Virginia while Virginia was underage MR PAGLIUCA Objection to the form and foundation You can answer A Try again please Are you saying that its an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was underage MR PAGLIUCA Objection to the form and foundation A Again Im telling you first of all it was a statement that was issued by my lawyer and through my lawyer I understand that Im asking you are you saying that its an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was underage Is that a lie MR PAGLIUCA Objection to the form and foundation You can answer A So I cannot testify to what Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and decided to put I can testify to what Virginias obvious lies are as regards to me I cannot make representations about all the many lies she may or may not have told about Jeffrey So is Virginia lying when she says is it an obvious lie when she says that she had sex with Jeffrey Epstein while she was underage MR PAGLIUCA Objection to the form and foundation A Again Im testifying to what I know to be true I can only testify to all the many lies she told about me I cannot testify to what lies she told about somebody else Given she told so many about me one can probably infer she is lying about everything So you think she is lying when she said she had sex with Jeffrey Epstein when she was underage MR PAGLIUCA Objection to the form and foundation A Again I can only talk about what I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential can positively say myself not what somebody else is going to represent When you were saying that she was her claims of having sex with Jeffrey Epstein were obvious lies are you saying she is lying about engaging in sexual conduct with Jeffrey Epstein when she was underage MR PAGLIUCA Objection to the form and foundation You can answer A Again this was a statement that was put out from my lawyer And I can only testify to the obvious lies that she says about me I cannot make representations about lies she says about someone else but she lies so many times about me one can probably infer she is lying about everything So is she not lying when is she telling the truth when she says she had sex with Jeffrey Epstein when she was underage MR PAGLIUCA Objection to the form and foundation A Again I dont know how else to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential tell you I can only talk about what I know to be true What I know is her story about how she claims that initial situation happened is so egregiously false and such a giant fat enormous repulsive disgusting inappropriate vile lie that that I can testify to Was she lying when she said she met you at Mar-a-Lago A Again I already testified I dont recall meeting her at Mar-a-Lago We showed you a document where you said you met her at Mar-a-Lago when she was is that correct MR PAGLIUCA Objection to the form and foundation A I think I already testified to that What I remembered based on all the rubbish she has written and all the many articles I have read maybe in the moment when I wrote that have caused me to have that but on reflection I dont recall it as I sit here today Are you saying that it was an Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential obvious lie that you approached Virginia while she was under age at Mar-a-Lago MR PAGLIUCA Objection to the form and foundation A First of all we can all agree here all of you sitting here that the lies that you perpetrated in the press that she was and we should all agree now that that is fake a lie that was perpetrated between all of you to make the story more exciting can we agree on that That is not my question A Can we agree she was not the age she said and you put that in the press that is obviously manifestly absolutely totally a lie MS McCAWLEY I am going to put on the record Ms Maxwell very inappropriately and very harshly pounded our law firm table in an inappropriate manner I ask she take a deep breath and calm down I know this is a difficult position but physical assault or threats is not appropriate so no Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential pounding no stomping no thats not appropriate A Can we be clear I didnt threaten anybody MR PAGLIUCA Stop you made your record there is no dent in the table I dont see any chips Can we take a break now MS McCAWLEY I think its appropriate to take a break THE VIDEOGRAPHER Its and we are off the record Recess THE VIDEOGRAPHER Its now were starting disk No and we are back on the record Ms Maxwell how old was Virginia Roberts when you met her in Mar-a-Lago MR PAGLIUCA Objection to the form and foundation A I know today that she was years old Are you saying that its an obvious lie that Virginia traveled on Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epsteins airplanes MR PAGLIUCA Objection to the form and foundation You can answer A Are you referring to my statement where that says that Im referring to the language you use in your statement that says obvious lies A Can you read my entire statement Sure let me pass it out Maxwell Exhibit email,marked for identification This is Bates GM and we will mark it as what you have in front of you is a statement at the top This was produced by your counsel it is indicated Bates No GM At the top the date reflects January from appears to be a subject line is you and then there is a number of individuals you can see at the top that are copied on this that is sent to and bccd on this statement The statement there are two parts Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential of it There is an opening email that says please find an attached quotable statement on behalf of Ms Maxwell and there is more language there and its from and then it says in the body of it Jane Doe No or Jane Doe is Virginia Roberts so not a new individual The allegations made by and it says Victoria but I believe that means Virginia Roberts against Ghislaine Maxwell are not true The original allegations are not new and have been fully responded to and shown to be untrue And the next paragraph says Each time the story is retold it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that is involved in having sexual relations with her which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicized as news as they are defamatory The last paragraph states Ghislaine Maxwells original response to the lies and defamatory claims remains the same Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Maxwell strongly denies allegations of the strongly denies allegations of an unsavory nature which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims Are you saying that its an obvious lie that Virginia Roberts traveled on Jeffrey Epsteins planes MR PAGLIUCA Objection to the form and foundation A Im saying whats an obvious lie and I think we can all agree you just had the case tossed out by He just got removed from the case because you put him in a case that he wasnt supposed to be in so what was said about him is not true Are you saying that its an obvious lie that Virginia Roberts traveled on Jeffrey Epsteins plane MR PAGLIUCA Objection to the form and foundation A You have given me plane records that has her name on it but as I already Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential testified those arent federally mandated things and I can see her name on it but thats what I I told you I dont recall her on any planes Is is that one of Virginias obvious lies A There are more obvious ones Is that one of them A I cant testify to her being on a plane or not So is that an obvious lie A There are more obvious lies like I understand there are more obvious ones Im asking you is the fact that she said she traveled on Epsteins planes an obvious lie A I think we can probably say because you see her name on a plane record and she went from A to that would not be the obvious lie that I would pick What obvious lie were you picking when you made this statement A There are so many that I would be Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential thrilled to go through all of them Lets go through them Whats the first one A Her characterization of the first meeting at Mar-a-Lago What part of that was an obvious lie A The characterization that she said that she said she was accosted She looked like as best as I can recall if I met her in Mar-a-Lago as she claims she worked at Mar-a-Lago she claims and her statement she worked at Mar-a-Lago she would have been dressed as all the spa people in Mar-a-Lago would have been It would have been impossible to identify her as someone other than someone who worked at a spa She made many claims she has been a bathroom attendant front of house attendant we dont know what she was so her obvious lies are her contradictory of her own personal statements within that So what part of her statement relating to Mar-a-Lago Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Im carrying on Im sorry I thought you were done A Please Her statement also that she was driven by her father to Palm Beach She was driven by her mother as a matter of fact Her whole entire characterization of the first meeting with Jeffrey as I was outside speaking to her mother Let me stop you there so we dont get too far ahead Let me make sure I understand your testimony The first in the first piece when you were talking I believe you said and correct me if Im wrong that her characterization of the first meeting at Mar-a-Lago was an obvious lie What part of that meeting was an obvious lie A By her own testimony all her various many different descriptions of what she was or wasnt or where she was or wasnt they have all changed She was either front of house or bathroom attendant I dont know Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential what she was so just by her own words one doesnt know whats true and what isnt true Are you saying what position she said she was working in is that what you are considering the obvious lie A I said inconsistency within her own statement from everything so in the beginning it starts off with different statements Then I believe you said the second piece was that she was driven by her father A I said she was driven by her mother Thats the obvious lie A Its an obvious lie to me You said why dont you state it in your own words but the characterization of how she was with Jeffrey what about that is an obvious lie A I was standing outside talking to her mother so the entire story is a fabrication Did she not have sex with Jeffrey Epstein during that first massage Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I was talking to her mother so Do you know whether thats an obvious lie whether she had sex in that room or not A Her story about what happened lets also be the story as first hit the press was that somebody else led her to Jeffreys room it was not me and then it turned to being me so we have an obviously important inconsistency lie in my thats how I would characterize a lie It cannot be me or somebody else it can only be one or the other Who is the other person she said took her to the room A Why dont you ask her Im asking you A How would I possibly know You are saying thats a lie A It was a lie in the papers she said it in the newspaper it was in the newspaper Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential How do you know she wasnt identifying you A She said somebody How do you know that somebody wasnt you A Why did it suddenly become me why not say it was me and be done with it So its a lie because she originally may not have named you and then named you later A Its obviously inconsistent to somebody who wasnt me How do you know it wasnt you A I know it wasnt me because I was talking to her mother But she then named you is what you are saying A Thats an obvious lie She named you A Its an obvious lie because I wasnt even in the house Is it an obvious who did lead her up to Jeffreys room while you were talking to her mother Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A You would have to ask Virginia I dont know if she was led up to his room You were standing with the mother is that correct A Thats correct Who was working at the house that day A A Would typically lead someone up to the room where Jeffrey was having a massage A I dont know she was led up to the room to have a massage She would have found her way on her own A I would suggest that that entire story never happened at all in any of its form If you stood outside with the mother what did you think happened inside then A I believe that somebody it wasnt me probably took her to meet Jeffrey Epstein Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did Jeffrey tell you that A No but that would have been a normal interaction I dont believe for a second I know her entire characterization didnt happen because I was outside talking to her mother the entire time Why would she have come for a massage and not given a massage MR PAGLIUCA Objection to the form and foundation A We are talking about her characterization of the first time that she came to the house If Im following you correctly youre saying she walked in and would have gone to its your assumption she would have gone and talked to Jeffrey and left A When I was working for Jeffrey typically he would meet someone before getting a massage from them to see if he wanted to have a massage from them typically So he would not have someone come Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential up to the room and start a massage A He would not So the young girls in the police report who say they came over and were led up to the room on the first day would they be wrong about that MR PAGLIUCA Objection to form and foundation A I cant comment what happened when I was not at the house I can only comment when I was at the house Was there ever a time where a woman came to the house for the first time to give a massage and Jeffrey had the massage that day MR PAGLIUCA Objection to the form and foundation A Can we talk about adult professional masseuses please Im asking whether adult or underage A Im not interested in talking about underage I can only testify to what I know professional masseuses adult I cannot Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential testify to anything else Why cant you testify to an underage girl that came over and was led up to the room for a massage MR PAGLIUCA Objection to the form and foundation A The police records you are referring to You are saying that didnt happen Youre saying I can only testify to adults that came for an interview and were led up to the room Why cant you testify to whether an underage girl was brought in for an interview and led up MR PAGLIUCA Objection to the form and foundation Go ahead A Can you reask the question Why cant you testify as to an underage girl who came over for an interview and then was then led up to the room for the massage A Youve mangled your entire question Can you please reask that in a way Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that I can answer it correctly Why can you not testify as to whether an underage girl you said you can testify as to females that were over the age of why cant you testify as to whether an underage girl came over for an interview and on the same day A I dont know what you mean by interview You just said that Jeffrey Epstein interviewed it was your word interviewed the masseuses before they gave massages is that correct A The word interview is making me Im English so you could have some difficulty understanding the way I communicate Im using your word A Then I will reuse it a different word He would meet them because receiving a massage is something you want to make sure you are comfortable with the person and so interview is not the correct word but you would meet them to have a conversation with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential them to see if you want to have a massage with that person Did Jeffrey Epstein ever meet an underaged girl and on the same day receive a massage from that girl MR PAGLIUCA Objection to the form and foundation A I cant possibly testify to what happened after I was not at the house If you are aware at any time you were at the house did you ever see that MS MENNINGER Let her finish the question A I can only testify to people who were adult professional masseuses who came to the house I cannot testify to something Im not party to and dont know about I can only testify to what I saw So when professional adult masseuse male and/or females would come to the house typically when I was there typically he would meet with them prior to have a conversation with them about their experience whatever to decide whether it would then A if he had Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential time for a massage at that time or whether he could have a massage at that moment Was Virginia an adult when she came over was she over MR PAGLIUCA Objection to the form and foundation A I think we established as of today we are all aware everyone in this room that she was So you have been present when a minor was brought over for a massage for Jeffrey A Can I say as you are able to have a massage at so she came as a masseuse Im not saying whether or not you are able to Im saying youve been present at Jeffreys home when an underage minor has come over to give him a massage A Thats just not how that works You are able to be a masseuse at so she came to give for a massage at you are able to come and give a massage Im not asking whether she is able to do it Im asking whether you were Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential present at the home when a girl under the age of came over for the purposes of giving a massage MR PAGLIUCA Objection to the form and foundation You can answer A You can be a professional masseuse at in Florida so as far as I am aware a professional masseuse showed up for a massage There is nothing inappropriate or incorrect about that and your mischaracterization of it I think is unfortunate How many teenagers did he have that were professional masseuses that worked in his home MR PAGLIUCA Objection to the form and foundation How many A First of all I am not aware of teenagers who worked in his home You are aware of Virginia Roberts and youve stated she was and she worked for him correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No I did not state that at all you are mischaracterizing my words and what I said What I said was that we can all agree and I think at this point there is not one person in this room however much you would like her to be younger to say she was not because that has been a very offensive thing that you have all done So she was At you are allowed to be a professional masseuse and as far as Im concerned she was a professional masseuse There is nothing inappropriate or incorrect about her coming at that time to give a massage Her entire characterization of her first time at the house was to me an obvious lie given it was impossible for her entire story to take place given I was speaking to her mother the entire she was at the house So it was impossible that day that first day she came and you were speaking to the mother for Virginia Roberts to have had sex with Jeffrey Epstein during the time that you were outside with her mother Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A You again are completely mischaracterizing I can only testify to what I heard obvious lies about me and her obvious lies about me are that she as you put out to the papers and every other which way went upstairs with her didnt happen So that to me is an absolute obvious lie I also dont believe that her her mischaracterization of the length of time she was there because as I recall she just met with Jeffrey and then left with her mother Thats my recollection So you were standing outside the entire time that Virginia was in the house is that correct A That is correct So can you testify as to whether or not do you know either from Jeffrey or any other source whether or not Virginia Roberts had sex with Jeffrey on that first day that she was at the house A We can categorically state Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential absolutely percent that she did not have any type of sexual relations as described by you in your court papers that took place because those allegedly according to her lies involved some aspect of me As I was standing outside with her mother the entire time her entire story is a lie Therefore to ask me what she did or didnt do during that time I can only testify to what she said about me which was percent false So lets not take the first time lets take the next time she comes A No no how can do you that when the basis of this entire horrible story that you have put out is based on this first appalling story that was written repeated multiply by the press that lied about her age lied about the first time she came lied about and characterized the entire first time I have been so absolutely appalled by her story and appalled by the entire characterization of it and I apologize sincerely for my banging at the table Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential earlier I hope you accept my apology Its borne out of years of feeling the pressure of this entire lie that she has perpetrated from our first time and whilst I recognize that was I hope you forgive me sincerely because it was just the length of time that that terrible story has been told and retold and rehashed when I know it to be percent false So not the first time she came but the second time she came or the third time or any time she came did you ever participate in a massage with her in Jeffrey Epsteins room A I have never participated at any time with Virginia in a massage with Jeffrey Have you ever participated at any time with Virginia in any kind of sexual contact or sexual touching with Jeffrey and Virginia A I have not So we were going through the list of obvious lies and you were talking about the first time which I believe we have Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential completed but you can add to that if you need to What other obvious lies did Virginia Roberts tell that you were referring to in your statement A Oh my goodness Well I think we can totally cover the story the story that I flew him with and there was a dinner with other people and that entire thing is percent fictitious I have testified for the record and Im happy to do it again that I have never flown myself as a pilot in a helicopter at any time anyplace at any time to any part of the world What other obvious lies were you referring to A She was referring to she is referring to a bunch of people I dont believe ever came to the island at any time ever I dont even know actually Just one moment I want to hear all of them but when you say you dont believe Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential ever came to the island do you know whether ever came to the island A never came to the island How do you know that A Jeffrey doesnt know him I dont know him and I think had I dont think had gone to the island during the period when I would have been involved in organizing a trip I would have been aware of it So go ahead you had another one A It would be easier if I could see do you mind if a take a reference at some of these newspaper articles or you just want me to go from memory Her entire characterization of what took place in London at my house with Was it an obvious lie that she was at your house in London A We cant really establish the photograph and all that I dont know if thats true if thats a real picture or not So you dispute that you were Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential actually photographed in your town home in London A I dont recognize that picture Im not sure if thats a real picture or not And have you talked to about that picture A We discussed Virginias entire tail and he asked me if he even knew her So did tell you that he did not have sex with Virginia Roberts A He doesnt even know who Virginia Roberts is Did he tell you that he didnt have sex with her A It would be difficult to have sex with someone you dont know He may not remember her A I think the inference is he didnt know who she was he didnt have any recollection of her whatsoever Has ever come to your London town home A Yes Ever being the entire time I owned my house yes Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Can I go on on her obvious lies If you have more A I have her entire characterization I took her shopping into Burberry and bought her a very expensive dress and if this photo were real and if this is I would never the outfit doesnt work at all so Do you not remember taking her shopping or are you saying its an obvious lie you know you did not take her shopping A I did not take her shopping I did not by her a handbag Did Jeffrey by her a handbag A Her accusation was that I did Do you know if Jeffrey bought her a handbag during that trip to London A I dont know what he did She accused me I cant physically remember buying a not for her not for anyone not for me Did you ever go shopping with Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont recall ever shopping with Virginia Did you have more to go over or did you want me to ask my questions A The entire characterization of what took place in my house in London would have been impossible Can I ask do you still have it the picture of the London town home with you in it Giuffre As you are looking at this picture Ms Maxwell as Im looking at it its on the right-hand side there appears to be a picture hanging on the wall do you recall that in your London town home A Its a little difficult to see Do you recall having a picture on the wall there by the room where youre standing A I do have a picture Do you recall on the left-hand side having a railing that looks like that with sort of a bubble wood top A I do Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential So are you saying that its an obvious lie that Virginias statement that she had sex with is an obvious lie A What Im representing is that her entire ludicrous and absurd story of what took place in my house is an obvious lie Including she had sex with A She claimed things took place in my bathroom in London Her characterizations is just not possible So youre saying its an obvious lie that she was telling an obvious lie when she said she had sex with MR PAGLIUCA Objection to the form and foundation The witness answered the question A Im saying within the context of all the stories she told this particular story back up she claimed we went out at night Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential She characterized that She then characterized things took place in my bathroom in the bathtub itself The tub is too small for any type of activity whatsoever A That would be A Yes Are you saying that it was an obvious lie when Virginia said that you made her dress up in a school girl outfit MR PAGLIUCA Objection to the form and foundation A I already testified that first of all I dont know what you are taking about I already testified I didnt get her outfits and all of that Is it an obvious lie that Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential was paid to go to give a massage to MR PAGLIUCA Objection to the form and foundation A I cannot testify to what Virginia did outside of I cant testify to what she did who she gave massages to So you dont know on that one A Of course I dont know Do you agree that its psychologically harmful to have sex with a minor MR PAGLIUCA Objection to form and foundation A What are you asking me Im asking if is it psychologically harmful for an adult to have sex with a minor MR PAGLIUCA Objection to the form and foundation A I dont know what you are asking This has nothing to do with Virginia Roberts It does A How does it Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential I ask the questions you answer If you cant answer you can say I dont know But my question is do you agree that its psychologically harmful to have sex with a minor MR PAGLIUCA Objection to the form and foundation A Are you giving me a random question and as not relates to this case and not relates to anything Its obviously not something that you want to have happen Do you agree that Jeffrey Epstein has harmed many minors by having sex with them MR PAGLIUCA Objection to the form and foundation A I cant testify to what Jeffrey did or didnt do I have no knowledge of what you are asking me If Jeffrey had sex with minors would you agree that that could harm a minor MR PAGLIUCA Object to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Again I am not testifying to what Jeffrey did or did not do because I cannot You dont know whether Jeffrey Epstein ever had sex with a minor A Again I cannot testify to what Jeffrey did or didnt do I cannot You never observed him having sex with a minor A I never observed Jeffrey having sex with a minor Do you agree that calling a sex abuse victim a liar when she speaks about her abuse can cause psychological harm MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Do you agree calling a sex abuse victim when she speaks about her abuse can cause psychological harm MR PAGLIUCA Objection to form and foundation A Say it again Do you agree that calling a sexual abuse victim a liar can cause psychological Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential harm MR PAGLIUCA Object to the form form and foundation A I would like to say all the terrible things Virginia Roberts said about me is extremely harmful and you should turn that around All the lies she has said and you have backed her on have been extremely damaging to me So what I can testify to is that somebody who has made these outrageous allegations and who is a serious liar and that I know for a fact is a liar that I can testify is damaging to me Do you agree that calling a sexual abuse victim a liar when she speaks out about her abuse can cause psychological harm MR PAGLIUCA Are you asking a hypothetical question MS McCAWLEY Yes A You are asking me to speculate Im not asking you to speculate If somebody is a sexual abuse victim A I cant testify to what some random Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential hypothetical person that you are asking me to speculate on their mental state or health versus speculative statement I cant do that thats just not right Do you agree that by calling Virginia Roberts a liar when she was subject to sexual abuse by Jeffrey Epstein can cause psychological harm MR PAGLIUCA Objection to the form and foundation Assumes facts not in evidence A I can only tell you about what I know of Virginias lies She lied repeatedly often and I know for a fact she is a liar so I can only testify to what I know and the fact that she has lied about me from the beginning to the end and repeatedly causes me to question anything that she may feel Is it an obvious lie you had sex toys in Jeffrey Epsteins Palm Beach house MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential please Is it an obvious lie that you had sex toys in Jeffrey Epsteins Palm Beach house MR PAGLIUCA Objection to the form and foundation A Did Virginia say that Im asking you a question Is it an obvious lie that you had sex toys in Jeffrey Epsteins house A I dont recall any sex toys If someone said had you sex toys would that be an obvious lie MR PAGLIUCA Objection to the form and foundation A Like I said can you be more specific about the house or whatever what exactly you are referring to whats a sex toy Yes How would you define a sex toy A No I need you to define a sex toy I dont have enough knowledge of sex toys Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential I will define it based on the dictionarys definition which is an object or device used to sexually stimulate or enhance sexual pleasure A Whats your question please The question is is it an obvious lie that you had sex toys in Jeffrey Epsteins Palm Beach house MR PAGLIUCA Same objection You can answer A Like I said I do not have any recollection of sex toys in Jeffreys house Is it a lie is it an obvious lie that you took pictures of nude girls MR PAGLIUCA Object to the form and foundation A We already covered this Girls we are not referring to I can only testify to taking pictures of adult people and I already testified they are not nude per se That every picture that I ever took and which they were very limited always by request the people would be covered or it would be a hand or a foot There was never any pictures that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential 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 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 Sure Is it a lie that you approached females to bring them to Jeffrey Epstein A I dont know what you are asking me Im asking you if its 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 You dont get to choose the questions Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I would like to answer your questions but you are not asking me a question that I can answer What about that is causing you pause where you cant answer the question A You are trying to trap me and thats not fair so I already testified that I hire people across the board so I would hire architects decorators pool people exercise instructors gardeners cooks chefs cleaning people So I in the course of a very long time when I would hire people I hired people to work for Jeffrey So Im happy to testify to hiring people for every possible conceivable proper job that you could conceive of within the context of Jeffreys life and homes Is it a lie that you approached females to bring them to Jeffrey Epstein for the purpose of performing massages MR PAGLIUCA Objection to the form and foundation A Again I have already testified that part of the job that I had was to hire Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential lots of different types of people In terms of whatever very small part of my job Jeffrey enjoyed getting massages I think that is something we can all agree in this room and within the context of that very infrequently I would go to spas and myself happily receive a professional nonsexual massage from a man and/or from a woman and if that massage was something that I thought was something that was good I would ask if that man or woman would come back and does home visits If that person said that they did they would sometimes come from time to time not always come back to the house to perform a nonsexual professional male or female massage Were any of the exercise instructors you hired under the age of A Again I dont hire weve already established that I dont hire people I interview people to see if they are competent in the job that they do and/or whether they are someone who seemed that they can do home visits Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential At the point where I think that there is somebody that has can be either whatever the job may be pool gardener chef and/or exercise instructor and I think they could be good at whatever it is at whatever skill that they had and they did a home visit which would obviously be mandatory and Mr Epstein would meet with them and decide if he wanted to have whatever skill it was that he would do it and then he would then either have them come back or hire them Were there any exercise instructors that worked at the home that were under the age of MR PAGLIUCA Objection to the form and foundation A Again I keep coming back to this that the people that I employed or not the right word the people I would meet to come and work at the house under any guise whatsoever again from any of the many positions that I filled were all over were adults When you say adults over the age Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential of A I think we can establish what adult would be You never interviewed or I know you dont want to use the word hired whatever your role was you brought in an exercise instructor that was under the age of 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 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 MR PAGLIUCA Objection to the form and foundation A I can only testify to when I was at the house Yes Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I can only testify to the years when I was present Right A And I can also only testify to people I personally either met and/or worked with and/or invited to find the correct word I dont know what the correct word is to come to do exercise or whatever it was at the house Of the people that I male and/or female that I brought were all appropriate and age appropriate adults Over the age of A Weve established them as an adult You are saying appropriate adults so we are clear you didnt hire or bring in or know of any exercise instructors that were under the age of at any of those homes A I am also testifying that when I was present at the house and with the people that I brought in were all age appropriate adults How do you define age appropriate adults is that over the age of can we Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential agree to that MR PAGLIUCA Objection to the form and foundation Are they under the age of A We already established that you can be a masseuse in Florida at age That does not make it inappropriate A Im not saying appropriate or inappropriate Im just asking if there were any exercise instructors that were under the age of A I am not aware if anybody was but I dont want to full out and say you oh she said we already established you can be a year old masseuse and have it not be something that is not appropriate So when you say that and then you go well you come back and say something now we can establish that Virginia was but you can be a year old legal masseuse but I am not aware to your point Who were the other year old masseuses that you were aware of A I am not aware of any Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Were there any year year old masseuse that you are aware of A I am not aware Any 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 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 Is it an obvious lie that Jeffrey Epstein had a sexual preference for underage miners MR PAGLIUCA Objection to the form and foundation A Can you ask the question again It is it an obvious lie that Jeffrey Epstein had a sexual preference for underage minors MR PAGLIUCA Objection to the form and foundation A Can you ask the question again Is it an obvious lie that Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epstein had a sexual preference for underage minors MR PAGLIUCA Object to the form and foundation A I cannot testify to what Jeffreys You dont know his preference A You handed me a stack of papers from the police reports and thats what Ive read but I have no knowledge direct knowledge of what you are referencing So you dont know you dont know in your own mind that Jeffrey Epstein had a sexual preference for underage minors is that correct MR PAGLIUCA Objection to the form and foundation Is that correct A Please ask the question again You dont know in your own mind that Jeffrey Epstein had a sexual preference for underage minors MR PAGLIUCA Objection to the form and foundation You have to pause Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential let me object answer the question Listen to her question pause I object you answer So you dont know in your own mind that Jeffrey Epstein had a sexual preference for underage minors MR PAGLIUCA Objection to the form and foundation You can answer A I cannot tell you what Jeffreys story is Im not able to Did Jeffrey Epstein have a scheme to recruit underage girls to use them for purposes of sexual massages MR PAGLIUCA Objection to the form and foundation A Can you ask me again please Did Jeffrey Epstein have a scheme to recruit underage girls to recruit them for sexual massages MR PAGLIUCA Objection to the form and foundation A Can you ask it a different way Did Jeffrey Epstein have a scheme Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential to recruit underage girls for sexual massages MR PAGLIUCA Objection to the form and foundation If you know A I dont know what you are talking about Is it an obvious lie that Virginia Giuffre was a minor the first time she was taken to Jeffrey Epsteins house MR PAGLIUCA Objection to the form and foundation A So weve already established that Virginia was and we have established that her mother brought her to the house and that she came as a masseuse age which is legal in Florida Would Jeffrey Epsteins assistants arrange times for underage girls to come to the house for sexual massages MR PAGLIUCA Objection to the form and foundation A What are you talking about Sure Would Jeffrey Epsteins Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential assistants I think earlier you mentioned we talked about who worked in the role as an assistant or Would Jeffrey Epsteins assistants arrange times for underage girls to come over the house for sexual massages MR PAGLIUCA Objection to the form and foundation A Again I read the police reports so this is all happening according to the police reports when I am no longer at the house so I cant testify to what Jeffreys assistants did when this kind of activity as alleged in the reports So you dont know A No Would Jeffrey Epsteins assistants meaning or any other assistant that you are aware of from the time you worked there take nude photographs of underage girls MR PAGLIUCA Object to the form and foundation A During what period of time Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential During any period of time you worked did you observe that A I did not observe any such photographs Are you aware if they took those kinds of photos A I am not aware MR PAGLIUCA Can we take a five-minute break THE VIDEOGRAPHER Its and we are off the record Recess THE VIDEOGRAPHER Its now Were starting disk No and we are back on the record Ms Maxwell was it an obvious lie when Virginia said she was sent to Thailand by Epstein in September of MR PAGLIUCA Objection to the form and foundation A I have no knowledge of Virginia being sent to Thailand But may I say something There is not a question pending Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential unless you want to clarify something Did you want to clarify that A No I just wanted to say something Is it an obvious lie when Virginia said she was given instructions to maintain telephone contact with you while she was in Thailand MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Is it an obvious lie when Virginia said she was given instructions to maintain telephone contact with you when she was in Thailand MR PAGLIUCA Same objection A I have no idea what instructions Virginia was given if any when she went to Thailand So you know she went to Thailand A I know she claimed she went to Thailand from having read it but given that she lied about everything its hard to know what is true and not true Would it make any sense for her to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential be in contact with you would there be any reason why she needed to be in contact with you MR PAGLIUCA Objection to the form and foundation A When are we talking about When she went to Thailand MR PAGLIUCA Same objection In would there be any reason for her to remain in contact with you MR PAGLIUCA Objection to the form and foundation A Can you ask the question again please Would there be any reason for Virginia to maintain contact with you in when she went to Thailand MR PAGLIUCA Same objection A First of all I didnt know that she went to Thailand I had had nothing to do with her trip to go to Thailand and there would absolutely no reason for her to be in touch with me whatsoever Did you ever have a phone number Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that was A I did Was that a cell phone number A Yes Is that your current cell phone number A Yes Im going to mark a couple of things here Maxwell Exhibit photos marked for identification THE WITNESS Can I say something now MR PAGLIUCA No THE WITNESS Will you let me know when I can MR PAGLIUCA When she asks you a question So weve marked this as Exhibit Im showing you whats been marked as Exhibit which is Giuffre and Can you take a look at that document for me Is that number that you just identified the as being Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential your cell phone number is that number on this document A It is And do you know who authored this document A I do not Who is A I dont know who is on this document because I dont know what this document is Do you know someone by the name of A I do know someone by the name of Would he know your phone number MR PAGLIUCA Object to the form A I have to idea Why would Virginia be instructed to call Ms Maxwell at your number on this form MR PAGLIUCA Objection to the form and foundation A I dont know what this document is I dont know when it was done I dont know anything about it other than I can see it has Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential my name and my number on it So you said is he employed by Mr Epstein A Again it is not the only one on the planet I understand Do you know a that is employed by Mr Epstein MR PAGLIUCA Objection to the form and foundation A Can you ask me the question again Do you know someone by the name of that was employed by Mr Epstein back in A I do know somebody who was employed by Mr Epstein known as Do you recognize the other numbers listed at the top of this document A I do not Would you have known cell number at that time in MR PAGLIUCA Objection to the form and foundation A I have no idea Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Can I ask you to turn to the next page please Do you know who is who is mentioned on this document A I do not If you look on the bottom lines of the document it says Still in Thailand during your stay if she is she will be staying at the same hotel Do you recall ever giving Virginia instructions to meet a girl in Thailand MR PAGLIUCA Objection to the form and foundation A I have already testified that I didnt even know that Virginia was going to Thailand So you didnt give her instructions to meet a girl in Thailand A Like I said I didnt even know she was going to Thailand Do you know whether Jeffrey Epstein would have given her instructions to meet a girl in Thailand MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I cannot possibly tell you what Jeffrey did or didnt do I wouldnt know Do you know whether Jeffrey Epstein paid for Virginia to go to Thailand A Again I wouldnt know if he did Maxwell Exhibit documents marked for identification Im going to direct you can take a look at it and then Im going to direct your attention to a couple of pages MR PAGLIUCA So the record should be clear this exhibit which is is and then skips to and So Im going to direct your attention to the first page have you ever traveled with Jeffrey Epstein where youve received a document like this from Shoppers Travel in your own independent travel Do you recognize this MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential The front form the front page do you recognize this Shopper Travel form have you ever used them as a travel agent with Jeffrey Epstein MR PAGLIUCA Same objection You can answer A I dont recognize this Turning to the second page which is the do you see at the top of that document where it says Jeffrey Epstein Epstein Madison Avenue 4th floor New York New York Is that an address you are familiar with that is Jeffrey Epsteins A I am Do you see below that travel on Singapore Airlines and you are going to have to go from New York JFK to Singapore Bangkok Do you see that MR PAGLIUCA What The first entry is going to be on September New York MR PAGLIUCA I see it MS McCAWLEY Im not talking to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential you Im talking to the witness A I see it To Singapore Bangkok A Singapore Bangkok Im afraid are not the same place Singapore then Bangkok Im going to turn you to page Giuffre its a little further back And do you see at the top where it says Epstein underneath Royal Princess change mine A I do Does this refresh your recollection that Virginia Roberts trip to Thailand was paid for by Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I can only testify to the piece of paper you showed me that has that information I cannot testify from direct memory When Virginia was traveling to Thailand which the dates again Im going to refer you back to the first page so you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential can see the dates MR PAGLIUCA Can you identify a Bates number please which was at the top says Im going to refer you at the same time to the flight logs which were marked the thicker document that looks like this with all the log entries on it Im going to refer you to page MR PAGLIUCA Thats Exhibit No correct Im trying to keep the record straight MS McCAWLEY I dont have Exhibit numbers on mine Thats Giuffre MR PAGLIUCA Hang on one second A Can you repeat the number please And if you will look on that page at the entry under starting with the and then it runs down to the looks like the that first entry has Jeffrey Epstein and the initials GM Do you remember taking a trip with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential during MR PAGLIUCA Objection to the form and foundation A Can you repeat the question please Do you remember taking a trip with during thats the it looks like through the A I dont remember the dates I couldnt testify to when we actually did it but I do remember the trip itself So you were traveling with Jeffrey Epstein and at the same time Virginia was headed to Thailand is that correct MR PAGLIUCA Objection to the form and foundation A I dont know is that right If you look at on the document that I gave you the first document and then you referred to if you look in the same as above lines you will see the travel group with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Are you asking her to compare the documents or are you asking her what her personal knowledge is MS McCAWLEY Im asking if she can look at the doubts and tell me if she recalls that she traveling with at the same time this document reflects Virginia was in Thailand A I cant testify to any dates I couldnt tell you I can see a date and I can see a date but I cant tell you that I have a memory of the dates I have a memory of the trip I dont have a memory of the time Who is A What is her address A I dont know Does she live in the United States A She does In what state A I believe in New Jersey somewhere Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you have her phone number A Not memorized Do you have the ability to get her phone number A Of course Has she ever asked has ever asked other girls to come over to see Jeffrey Epstein for the purpose of a sexual massage MR PAGLIUCA Objection to the form and foundation A Can you ask the question again please Has ever asked girls to come over to see Jeffrey Epstein for the purpose of a sexual massage MR PAGLIUCA Object to form and foundation A Can you ask again please Has ever asked girls to come over to see Jeffrey Epstein for the purpose of sexual massage A I have no personal knowledge What does do for you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A She helps with my not-for-profit ocean foundation and any other related activities that I may have Is she paid for by Jeffrey Epstein A No She is paid for by you A Yes When did you first meet A I dont recollect exactly sometime maybe How did you meet her A I dont recollect exactly how we met Did Jeffrey introduce you to her A I dont recollect how we met Does she know Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A Can you ask again please Does know Jeffrey Epstein A What do you mean by know Has she met her him before Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I cant recollect a time when Ive seen with Jeffrey but You are not sure A I know they know either other I cant testify to a meeting between them Do you know where in New Jersey she lives A No You dont know a city A No How long has she worked for you A Sometime To the present A Yeah Why do you think that might know Jeffrey MR PAGLIUCA Objection to the form and foundation A Because you know I know Jeffrey Have you seen them together A I already testified I have not seen them together to my recollection Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Is it your testimony that knows Jeffrey Epstein through the work that she does for you MR PAGLIUCA Objection to the form and foundation A I dont recollect and I dont recollect how I met and I cant testify to what relationship is or is not with Jeffrey Have you ever talked to Jeffrey about A I dont know what you mean In any way have you ever had a conversation with Jeffrey about A In what context In any context Have you ever talked to Jeffrey Epstein about A works for me so its entirely possible that in the course of conversations since that a conversation in which name would have come up is entirely possible I provided you with and Im sorry I dont know all the numbers but the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential statement that was issued by that should be a single page still in your stack of exhibits there MR PAGLIUCA Exhibit Did you authorize to issue that statement on your behalf in January of A I already testified that that was done by my lawyers So did you authorize your lawyers to issue a statement on your behalf through in January of A It was determined that I had to make a statement in the United Kingdom because of the appalling lies and I just thought of some new ones Virginias statement that I celebrated her birthday with her We can all agree that thats entirely impossible I didnt meet her until she was and other lies she perpetrated that she had a diary and we all know is a complete fake Thats not a diary It was just a book she was writing that you helped sell to the press as if it Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential was a diary when it was just a story that she is writing of fiction fictional story for money How did you arrive at the words that were put in that statement MR PAGLIUCA Im going to object and instruct you to the extent this calls for any privileged communications between yourself and or another lawyer representing you were asserting privilege If you can answer that without that feel free to answer So what your counsel is saying and I will exclude any privileged communications you had with your lawyers The question is how did you arrive at the words that were put in that statement if you can tell me without disclosing privileged communications A Im not sure that I can Is the statement that you issued true A What do you mean by that Is the statement that you issued Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential the statement thats in front of you is it a true statement A As in that Virginia is a liar The words you put in there is that true A Of course theyre true When did you become aware that the statement was being released A I dont recollect exactly What day it was A No Im sorry Did you identify I might not have caught it did you identify the name of the lawyer that you said you retained for purposes of this statement A I think Did you pay that lawyer A Yes Are you aware of any interstate or international transportation of a woman aged to for the purposes of prostitution MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Im not sure I even understand your question I will go slower Are you aware of any interstate meaning between states or international meaning oversees transportation of women aged to for the purposes of prostitution MR PAGLIUCA Objection to the form and foundation A Are you asking Im still not sure I understand the question I will try to make it clearer Im asking you if you are aware of any interstate meaning between states or international transportation meaning by flight or by car or by train of women aged to their ages are between the ages of and for the purposes of prostitution MR PAGLIUCA Objection to the form and foundation A In the world Im sure that that happens I read about it all the time Not in the world Are you aware of Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential it in your experience with Jeffrey Epstein of any interstate or international transportation of women aged to for the purposes of prostitution MR PAGLIUCA Objection to the form and foundation A So whilst I appreciate this might not seem like a smart question what do you mean by prostitution what are you asking me exactly That would be sex for hire any kind of sexual act thats paid for MR PAGLIUCA Objection to the form and foundation A Whos paying what are you asking me It can be paid for by anybody Its a sexual act thats paid for Im asking if you are aware of any interstate or international transportation of women aged to for the purposes of prostitution MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have no idea what you are talking about So you are not aware of that A No Are you aware of any interstate or international transportation of women aged to for the purposes of having sex with Epstein where they would receive compensation of any type MR PAGLIUCA Objection to the form and foundation A I dont know what you are referring to Do you want me to repeat the question A Sure go ahead Are you aware of any interstate or international transportation of woman aged to for the purpose of having sex with Jeffrey Epstein where they would receive compensation of any type MR PAGLIUCA Objection to form and foundation A I am not aware of what you are Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential talking about Are you aware of any interstate or international transportation of women aged to for the purposes of providing a massage for Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A So I you need to repeat that question for me Sure Are you aware of any interstate meaning between states or international oversees transportation of women aged to for the purposes of providing massage for Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I think we can agree he did travel from time to time with a professional adult masseuse Are you aware of any interstate or international transportation of women aged to for the purposes of providing a massage to any person other than Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epstein MR PAGLIUCA Objection to the form and foundation A Again Im not aware of anybody that if you are asking for specifics to someone else I have no knowledge of that So you are not aware of any interstate or international transportation of a woman aged to for the purposes of providing a massage to any person other than Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I dont recall what any single person being on a plane for a massage with someone else other than Jeffrey for the sole purpose if thats the question I dont have any recollection of that Earlier in your testimony you stated that Virginia Roberts was at the time you met her How do you know she was MR PAGLIUCA Objection to the form and foundation And to the extent Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that calls for a privileged response Im instructing you not to answer How do you know Virginia Roberts was at the time you met her MR PAGLIUCA Again if you learned that information from your lawyer Im instructing you not to answer A I will follow my counsels advice Are you able to answer that question without telling me information you learned from a lawyer A Im not So you dont have independent knowledge that Virginia according to your statement was at the time you met her A Again my lawyer has instructed me not to answer Im asking you a different question Whether you have any independent knowledge outside your lawyers that Virginia was at the time you met her A Following the instructions of my lawyers I can only remember or testify to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential what she MR PAGLIUCA She is asking you a different question She is asking other than what your lawyers have told you do you have any knowledge about her being thats what she is asking A I cant recollect where I got all the information that I have that definitively shows that Earlier in your testimony I believe you said all of us would know that Virginia was at the time you met her How would we know that A I think you know that by her own dates now that it was in so her entire tail of me celebrating her 16th birthday is clearly another giant falsehood But she was and that year wasnt she A Which year You said it was A I think the information that I have that indicates that definitively was something that is privileged so I cant Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential share with you So you have privileged information that definitively tells you that she was at the time you met her A I believe I do How would we know that A What are you asking me Earlier today you testified that we would know that she was at the time that you met her How would we know that A I imagine you have access to exactly the same information that I do What is that information A Again its privileged I cant share it with you but you have been on this case for I dont know much much longer than I have and I imagine you have all the information that I do Do you know whether your lawyers have produced documents from you that would show the age that Virginia was at the time that you met her MR PAGLIUCA To the extent that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential calls for a communication that you had with one of your lawyers Im instructing you not to answer that question I assume you as part of the discovery process had to collect documents that were relevant to this action is that correct A I did Did you collect documents that would show that Virginia was at the time that you met her A I think you have everything that relates that I had contemporaneously per what you asked for that I have that relates to that Did you have a document that identified that Virginia was at the time that you met her A You have all of the documents that I had Im not asking what documents Im asking do you have a document that identifies Virginia being at the time you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential met her A You have every document that I have You have seen every document that I have Thats not what Im asking A I dont recall every document that I gave you so I dont know I would have to look at every single document I gave you and then review it but as I recall you have every document that I have What are you planning to show the jury that will prove that Virginia was when you met her A Again thats privileged so I cant share that with you If youre showing the jury it wouldnt be privileged so is there a document you have produced in this matter that shows that Virginia was at the time you met her MR PAGLIUCA She answered that question already She said she doesnt know she has given you everything If there is a decision assuming for the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential moment there is such a document just hypothetically and assuming for the moment that it is going to get produced somewhere if it hasnt already been produced obviously that would involve a waiver a future waiver of the privilege I think thats the answer to the question Has the document been produced do you know A You have everything that I have given you so if you cant if its not in those documents I dont know what to tell you Your lawyers havent withheld any documents A They are right here You can ask them Im asking you A I dont know what theyre lawyers When we were talking earlier about I asked you whether you had ever given him a gift of a puppet Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you ever not as a gift did you ever see in the presence of a puppet MR PAGLIUCA Objection to the form and foundation A Can you be more direct please Sure Were you ever in a room with where there was a puppet MR PAGLIUCA Objection to the form and foundation A Can you be more specific please and can you bound it by time and be more specific whatever you are actually asking me Were you ever in a room with in New York in Jeffrey Epsteins home where there was a puppet MR PAGLIUCA Objection to the form and foundation A What sort of puppet are you asking me Any kind of puppet A You need to be more descriptive I dont know what you mean by puppet there is Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential hand puppets all sorts of puppets Is there any puppet youve ever seen in Jeffrey Epsteins home in the presence of A Again puppet you know there is lots of types of puppets Any type of puppet A If you want to give me a description of the puppet I would be perhaps be able to say Any type of puppet A Can you be more detailed Have you ever seen a puppet in Jeffrey Epsteins home in the presence of A My understanding of a puppet is a small handheld item you have in a circus I have never seen that Have you ever seen a puppet which is defined as a movable model of a person or animal that is used in entertainment and typically moved either by strings or controlled from above or by a hand inside it MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I have not seen a puppet that fits exactly that description Have you seen any puppet that fits any description MR PAGLIUCA Objection to the form and foundation A Can you reask the question please Yes Have you seen any puppet that fits any description in the presence of in Jeffrey Epsteins home MR PAGLIUCA Objection to the form and foundation A I am not aware of any small handheld puppet that was there There was a puppet not a puppet there was a I dont know how would you describe it really I dont know how would you describe it Not a puppet I dont know how you would describe it A caricature of that was in Jeffreys home Did you use that caricature to put the hand of the caricature on Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential breast MR PAGLIUCA Objection to the form and foundation A I dont recollect I recollect the puppet but I dont recollect anything around the puppet You characterized puppet I characterize it as I dont know as a characterization of Do you recollect asking Virginia Roberts to sit on lap with the caricature of A I do not recollect that What do you remember about the caricature of the caricature when you were in the presence of Virginia Roberts and MR PAGLIUCA Objection to the form and foundation A I dont recollect the story as told by or Virginia I dont even know who I remember the caricature of and I remember but I dont recall anything else around the caricature Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you give it to him A I did not Who gave it to him A I dont think it was given to him at all Did he bring it A No Was it something that was at the house A As best I recollect Was it something that you saw at the house in advance of arrival A Again I dont real I recollect the caricature I recollect I dont recollect much else around the caricature Was there a party going on in the house at the time you recollect the caricature MR PAGLIUCA Objection to the form and foundation A You have to be way more specific Do you remember you said you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential recollect this caricature you recollect being there Do you recollect a party going on at the time of that interaction with and the caricature MR PAGLIUCA Objection to the form and foundation A I dont recollect a party first of all they werent really parties I dont recollect a party I dont know what you mean by party in the context of that scenario Who do you recollect being at the home during the time was there with this caricature MR PAGLIUCA Objection to the form and foundation A I only recollect myself with I dont recollect anybody else You dont recollect Jeffrey Epstein being there A Actually no You dont recollect being there Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No You dont recollect Virginia Roberts being there A No It was just you and A I am not saying it was just me and you are asking me do you remember I only remember I remember and the caricature but I cant place the caricature and everybody else in the same context the same timeframe you are asking me MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Typically there is no typical because there is no standard procedure so I cant comment or testify to Do you remember them being in the house A Not specifically Do you mind if I take a bathroom break THE VIDEOGRAPHER Its now and we are off the record Recess THE VIDEOGRAPHER Its now We are back on the record and were starting disk No Ms Maxwell during what time period I know you said I believe you said you met Jeffrey in if Im correct there and youve known him through the present During what time period within those years would you say your relationship was the closest with Jeffrey MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential A What do you mean by close sorry I think earlier today you testified that at some point in time you considered yourself to be his girlfriend is that the closest you would say that your relationship was with him and if so what time period was that MR PAGLIUCA Objection to the form and foundation A I dont think I said I was his girlfriend I would like to think of myself as maybe I dont think I sometime in the mid How close was your relationship A We were very friendly Without going into details was your relationship with him intimate A Yes When was the last time you had contact with Jeffrey Epstein A What do you mean by contact Either a phone call or email or anything of that nature A As best as I can recollect when Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential all sometime last year So you havent talked to him like for example last week you didnt talk to him A I did not How many times have you had either direct or indirect meaning in the presence of him or calling or emailing contact with Jeffrey Epstein from December until now A Im sorry can you just Either in person or by phone or by email from December until present A I cant really characterize that but not very much There was a period when in January when you filed your whatever you filed where we spoke and then since then not much at all Can you estimate how many emails you would have sent Jeffrey from the period of December to the present A Not very many at all More than A I really wouldnt be able to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential characterize it because it wouldnt be that many I wouldnt know More than A It would be on the lesser side not on the more side Can you give me a number A I honestly couldnt I would be guessing How many emails has Jeffrey sent you from the period December to the present A I would say less emails even less emails than I sent him More than A I would say on the lesser side Less meaning A I really cant recall very little When you spoke with Jeffrey in January of what did he say to you A I really couldnt remember exactly what he said to me Did you talk about Virginia Roberts A Im sure we did but I couldnt Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential recall the exact conversation Does Jeffrey Epstein send you text messages A No Do you send him text messages A No How many phone calls have you had with Jeffrey Epstein since December A Again very few More than five A Probably as many as the few emails that I would characterize so just very few I mean a small number Are you aware of any disagreement between your views about Virginia Roberts and Jeffreys views about Virginia Roberts MR PAGLIUCA Object to the form and foundation A I cannot speculate to his views I can only testify on my views Earlier you went through the series of lies Have you talked to Jeffrey about the lies and does he agree with you A I have discussed some of the issues Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential with him I cant remember specifically which ones I just dont recall Im sorry Do you recall him telling you that he didnt agree with you on any of those A I dont recall him saying that Do you have a joint defense agreement with Jeffrey Epstein A I believe I do Do you have a joint defense agreement with A I dont believe I do Earlier today in your testimony when I was asking you some questions you said that you couldnt answer but that Jeffrey Epstein could answer that question Would Jeffrey Epstein be in a position to confirm or deny some of the obvious lies that weve discussed today MR PAGLIUCA Objection to the form and foundation A I cant possibly testify to what Jeffrey could or would say I cant speak for him Would Jeffrey be able to confirm or Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential deny whether he had sex with Virginia Roberts MR PAGLIUCA Objection to the form and foundation A I cant say what Jeffrey would say Has he discussed that with you A He has not Would Jeffrey be able to confirm or deny whether he had a sexual massage from Virginia that first time she came to his mansion in Palm Beach MR PAGLIUCA Objection to the form and foundation A I cannot speak for what he would say I can only speak for what I would say So as I testified everything that she said about that first meeting didnt happen so Has he told that you everything about that first meeting didnt happen A I know it didnt happen because she put me in that room I understand you know But has Jeffrey said when you are talking about the obvious lies oh yeah that never happened Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I cant specifically recall that I dont know but he has to agree with me because it didnt happen Can Jeffrey Epstein would he be able to confirm or deny whether he had sex with underage girls MR PAGLIUCA Objection to the form and foundation A I cant testify to what Jeffrey would say Can Jeffrey confirm or deny whether was on Jeffreys island MR PAGLIUCA Objection to the form and foundation A I cant say what Jeffrey would say I can only say what I know to be true Has Jeffrey talked to you about the fact whether was on his island A As best as I can recollect he said he was not on the island As best as I can recollect Can Jeffrey Epstein confirm whether Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential he and Virginia Roberts were together in the presence of MR PAGLIUCA Objection to the form and foundation A I cant speak to what Jeffrey would say Has he talked to about Virginia Roberts statement that she was in the presence of MR PAGLIUCA Objection to the form and foundation A I have not discussed individual presences with Virginia Thats not Im only concerned with what I know to be the stuff about me So my focus has always been the lies and the obvious lies as something I can personally attest to I cannot possibly talk for anything else Has Jeffrey Epstein said to you anything along the lines of Virginia is lying when she says she met MR PAGLIUCA Objection to the form and foundation A Again Im not talking about what Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential she says as regards to other people I can talk to things as regards to me Im asking if Jeffrey ever said that to you A I dont recollect specific conversations along those things You dont recollect him saying that to you A I dont recollect him saying to me that Virginia didnt meet Im sure that wouldnt be a conversation that we would have It doesnt effect me whether so Im really only concerned about the lies that were told as regards to me Can Jeffrey Epstein confirm or deny whether you sent Virginia to give a massage MR PAGLIUCA Objection to the form and foundation A I cant say what Jeffrey would say I can tell you I didnt I cant tell you what anybody else Have you discussed with him Virginias allegation that she gave Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential a massage MR PAGLIUCA Objection to the form and foundation A I didnt know that she did say that Do you know whether Jeffrey Epstein has ever sent anybody to to perform a massage for him MR PAGLIUCA Objection to the form and foundation A I couldnt possibly recollect whether he did anything like that Did you ever send anybody not Virginia anybody else over to home for a massage A Not to the best of my knowledge Do you know one of friend by the name of A I do recollect a person of that name How do you know her A I dont recollect Did you meet her through Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont recollect Do you recall when you met her A I do not recollect How many times have you seen in your life A The only reason I remember is because its an unusual name but I couldnt tell you anything else You didnt see her on a regular basis she wasnt one of your friends A No Was a masseuse A Not to my knowledge Do you have knowledge of whether she had a sexual relationship with Jeffrey Epstein A I have no knowledge of that When was the last time you spoke with her A A very long I have no idea Would it be years A Yes What do you remember about Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Nothing really Do you remember what she looks like A I would just be speculating on how I remember I couldnt describe her Do you recall traveling with her A I dont Did you ever go to her home A I dont believe I did Do you know where she lives A I dont Would you have met her through Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I already testified I dont recollect how I met her and I remember her because her name is very unusual So whats your what recollection do you have of her do you have a specific recollection of meeting her somewhere you just dont know when that was or how do you know that name MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I dont know why the name is Im sorry I cant I have no idea I recognize the name but thats it Was a masseuse MR PAGLIUCA Objection to the form and foundation A What are you asking me Im sorry When worked for Jeffrey Epstein did she perform massages A Ive testified that when came originally she came to answer telephones I believe at some point she became a masseuse I dont recollect when and I personally had massages from What did do for Jeffrey Epstein did she perform massages anything else MR PAGLIUCA Objection to the form and foundation A When she came she answered phones and at some point I believe I dont have any firm recollection but I believe she went to school and became a masseuse and I had Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential massages from her Did you ever have any sexual interaction with her MR PAGLIUCA Object to the form and foundation and Im going to instruct you if were talking about any consensual adult contact you are not allowed to answer the question Did you have any sexual contact with her in the presence of Jeffrey Epstein MR PAGLIUCA Same instruction Did you have any sexual contact with her in the presence of anybody other than Jeffrey Epstein MR PAGLIUCA Same instruction How many massages did you receive from A I really dont recall but a fair amount Did the massages involve sex MR PAGLIUCA Im going to instruct you not to answer Have you ever engaged in sex with any female Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Im going to instruct you not to answer MS McCAWLEY I want the record to reflect that Ms Maxwells attorney is directing her not to answer this series of questions MR PAGLIUCA It definitely does Were you responsible for introducing to Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I already testified that I dont really recall Were you responsible for introducing to Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A Again I dont like the characterization of introduction came to answer telephones When did you were you the person who brought or introduced or met for purposes of bringing her to Jeffrey Epsteins home Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A Thats not how I would characterize that How would you characterize it A I have testified that Im responsible for finding professional people to work in the homes age appropriate adult people so from pool attendants to gardeners to chefs to housekeepers to butlers to chauffeurs and one of the functions was to be able to answer the telephones and in the context of finding someone to answer the telephones I did look to try to find appropriate people to answer the phones So did you find Johanna for purposes of that role A So in the course of looking for somebody to answer phones at the house Johanna was one of the people who said that she was willing to answer phones Did you approach her at her school campus Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to form and foundation A I honestly dont recall how in that moment how I met and how she came to get the job but Did you typically in your work for Jeffrey Epstein would you typically go to school campuses to try to find individuals to work for Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I never what do you mean by school Lets characterize school Any kind of school A Obviously not I never went to any school with young people I believe came from an adult university as I would know in England so university I went there but I never went as I best recollect anywhere else Did you what university was it that you went to A I dont recall the university that she went to right now Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Would you visit more than one university to try to find individuals to work for Jeffrey Epstein A As I recollect I think thats in fact the only university I went to Did you go there more than once A I think I went twice Who else did you find from that university was there anybody other than A I dont recollect Im sorry We are going to mark this as Maxwell Maxwell Exhibit documents marked for identification Can you take a look at the document I put in front of you please Are you familiar with this document A Im familiar with this actual document How was this document created MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont know how this document was created You were involved in the creation of this document A I think you can see from the date that its so no You werent involved in the creation of this document Did you we talked earlier about Mr Epsteins house Im talking about the Palm Beach house where you said there was a computer on the desk that employees had access to people who worked for Jeffrey Epstein may have had access to A I think anybody could have had access to that Was that computer used if you know to keep a log of addresses and phone contact information for Jeffrey Epstein A Are we talking about when this document was created In general was there on that computer during the time that you were present with Jeffrey Epstein was there a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential mechanism by which you kept electronic information of names and addresses of individuals that he knew MR PAGLIUCA Objection to the form and foundation A I cant testify to what was on that computer or not after I was gone Not when you were gone when you were there If Jeffrey wanted to call for example say would someone be able to go to that computer to pull up the address information and phone contact information for that individual MR PAGLIUCA Objection to the form and foundation A I couldnt possibly say Did you ever have to keep track of address or phone contact information for Jeffrey Epstein A That was not my job Did you ever do it A I am not responsible for keeping his numbers so that wasnt my job at all But did you ever do it I know Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential its not your job but did you ever do it did you ever keep phone contact information for him A During the course of the time we were together if he gave me a telephone number I would give it to an assistant to put in the computer I could do that Would he ask you for contact information for different individuals if he wanted to contact someone MR PAGLIUCA Objection to the form and foundation A In the course of the long period of time when I was there it certainly would be possible for him to ask me for a telephone number and if I had the I wouldnt always have it Im sure it happened Was there a hardcopy book in addition to the computer a hardcopy book that you could look for numbers that were relevant to Jeffrey Epsteins life and something on the computer or was it just an electronic version MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation Was there a hard copy book as well as something on the computer or was there only electronic information on the phone numbers MR PAGLIUCA Objection to the form and foundation A I can only testify to what I know obviously and I believe that this is a copy of a stolen document I would love to know how you guys got it Im asking during the time you worked for Jeffrey Epstein was there a hardcopy document of any kind that kept phone numbers for Jeffrey Epstein if he needed to contact someone A The stolen document I have in front of me that you have is what you are referring to So there was during your time when you were there there was no other you mentioned there was information on a computer Was there any hardcopy document that you could refer to to find someones Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential number A You have the stolen document in front of you You had access to this when you worked for Jeffrey Epstein A This is I believe the book that was stolen that was the hardcopy of whatever was there So when you were working for Jeffrey Epstein you were able to access this book A This book if this is what this is I believe it was this is the stolen document from his house And you were able to access it when you worked for him A It was a document that was printed that you could if you needed to look for a number Do you know how this book was created A No When you referred to it a moment ago to a stolen document when Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential turned this document over to the FBI are you aware he described it as a document that came from your computer MR PAGLIUCA Objection to the form and foundation A I have no idea what he said or didnt say so if you want me to reference something he said you need to show it to me Did you keep this document an electronic copy of it on your personal computer A I dont recollect If you had to update something for example if there was a new number a new individual that Jeffrey had hired that you were going to track would you input that information into this document on your computer MR PAGLIUCA Objection to the form and foundation A Ive already testified that Im not responsible for updating and keeping these records Did you have this document on your Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential computer your personal computer A I told you I dont recollect having this document on my computer Do you know what computers this document was on if more than one A Im sorry this is a long time ago and I dont recall exactly how this was all managed If you didnt create this document do you know who did MR PAGLIUCA Objection to the form and foundation A I dont Im going to direct your attention to part of this document Its towards the back its going to be page and it has bates label Giuffre Im going to direct your attention to the section that says Massage Florida Did you input any of the names or numbers under that section MR PAGLIUCA Objection to form and foundation A So this document is produced in Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential so no But Im sorry correct me if Im misunderstanding your testimony I thought you said when you were working with Jeffrey that this document existed and it was something you utilized A I cant possibly tell you what numbers were added or not added subsequent to my departure So you cant recall if you added any of these numbers MR PAGLIUCA Objection to the form and foundation mischaracterizes the witness testimony Are there any numbers on here or names that you recognize that you would have entered into this section A I already testified that Im not responsible for inputting numbers and names into this so I would not be able to tell you Are there any names or numbers under this section Massage Florida that you would have provided to an assistant to input into this document Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I cant possibly say Do you see under Massage Florida about halfway down the first column do you see a number that says cell MR PAGLIUCA What page Its Bates number About halfway down it says in the first column it says cell Do you see that A I do Would you have provided after I know you didnt hire her Jeffrey hired her but after you brought her to Jeffrey would you have given her cell phone number to an assistant to input into this document MR PAGLIUCA Objection to form and foundation A I didnt bring her to Jeffrey the way you characterize and I would have no knowledge of how this number ended up in this book I believe you and I will try to use your words so we are clear you met is that correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Yes And then she began working for Jeffrey A Yes Would you have provided whomever was in charge of keeping this updated with cell number so you would be able to contact her if needed MR PAGLIUCA Objection to the form and foundation A I dont know It could have been a number of different ways it it could have been Jeffrey who gave it to somebody You just dont remember doing that A I do not Now as you look I want you to take a look at the Florida massage list its three columns there Do you as you look at those names on the various columns do you know the ages of any of the girls in this list A I dont know One I dont know who all the people are on this list and I certainly dont know the ages Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you know what their qualifications are A I dont know who the people are in general so of course I dont know what their qualifications are Do you know why Jeffrey has so many masseuses listed in Florida in his book here MR PAGLIUCA Objection to the form and foundation A Again this book was created post my departure so I couldnt explain why all these people were here When you were there you said this book existed A Yes So when you were there were there a number of masseuses listed under the Florida massage MR PAGLIUCA Objection to the form and foundation and mischaracterization of the witness testimony Im asking you a question When you were there were there a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential number of masseuses listed under the Florida massage section A When I was there I would have of course there would have been some masseuses listed but I could not tell you who or how many and this I could not possibly because I wouldnt remember Do you know why Jeffrey would have had so many names listed under his massage Florida MR PAGLIUCA Objection to form and foundation A I cant testify to why Jeffrey has so many Did he use a different masseuse every day MR PAGLIUCA Objection to the form and foundation You can answer A When I was there he had a massage roughly every day one masseuse and mostly he would have them at random times so it would be difficult if you just only had one person man woman for an adult massage to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential come and be available for whatever time it was So he would have more than one person that he could call for a massage because at any given time the one that he called first may not have been available So would it typically be a different person each day that would give him a massage MR PAGLIUCA Objection to the form and foundation A It would be when I was there based on availability Would it surprise you to learn that the Federal Government found that some of the girls on this list under massage Florida were under the age of MR PAGLIUCA Objection to the form and foundation A I cant testify to what the government found or did not find because I would have no knowledge of it Im asking if you would be surprised by that MR PAGLIUCA Form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have knowledge of it I cant speculate On the second column towards the bottom there is the name its one up from the bottom there is the name do you know A I do Who is she A She was a friend of Jeffreys Is she a masseuse A She I dont think she was a masseuse no Why would be she listed under Florida massages A An input error Is this list any individual that would have sex with Jeffrey MR PAGLIUCA Objection to the form and foundation A I wouldnt have any knowledge of that Do you know if Jeffrey had sex with MR PAGLIUCA Object to the form Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential and foundation A First of all I wouldnt have any knowledge of that MS McCAWLEY We are going to take a quick break THE VIDEOGRAPHER Its now and we are off the record Recess THE VIDEOGRAPHER Its now and we are as back on the record starting disk number Ms Maxwell we were talking earlier about the journal and I believe you said in you were no longer working and responsible for that journal is that correct MR PAGLIUCA Objection to the form and foundation A What are we referring to this document right here Yes A I dont know who is the author of this or I cant tell you what is in here versus what would have been here when I was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential around I cant testify to that Were you around in A I already testified that I was there when Jeffreys mother passed away and so you know I did visit for her passing and I believe I was there for a couple of days in So if an employee of Mr Epstein in said that you were the employees direct supervisor would that be incorrect MR PAGLIUCA Objection to form and foundation A What employee whats the circumstances and what is the story I dont know what you are asking me If said in when he was hired you were his direct supervisor would that be true A No Were you in supervising MR PAGLIUCA Objection to form and foundation A I never supervised Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did take orders from you MR PAGLIUCA Objection to the form and foundation A She worked for Jeffrey If said you had knowledge of underage girls coming to Jeffreys home for the purpose of sex would you contend that that is truthful MR PAGLIUCA Objection to the form and foundation of the question A I have no idea what you are talking about Im sorry If said that you have knowledge of underage girls coming to Jeffreys home for the purpose of having massages involving sex would you say that that statement is truthful MR PAGLIUCA Objection to the form and foundation A I cant testify to what said or didnt say Im saying if said that you had knowledge that there were girls coming Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential over to the house that were underage for the purposes of sex would that statement be true MR PAGLIUCA Objection to form and foundation A I cant testify to what said or didnt say or what he thought Did you have knowledge of underage girls coming to Jeffrey Epsteins house for the purpose of sex A No Earlier I believe you testified correct me if Im wrong that the document that is in front of you the thicker document was a stolen document Do you know who stole that document A I have read that stole the document And where have you read that A I believe it was reported in the press Earlier we were talking about the computers at Jeffrey Epsteins home Did you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential have a computer that was your computer located in Jeffrey Epsteins home MR PAGLIUCA Objection to form and foundation A Ive testified to the computer already Even when I was around there was a computer that people had access to So is telling the truth when he says that he downloaded that book from your computer MR PAGLIUCA Objection to the form and foundation A I couldnt possibly tell you what did or didnt do or said or didnt say Was it on your computer A I already testified I have no idea where this document came from Did you have a list of names of individuals with contact information for Jeffrey Epstein on your personal computer A Again that wasnt my computer I already said that was a computer that lots of people would have so I have no recollection Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential of this document being on it so I dont know where this came from I understand the computer at the house that youre referencing On a personal computer of yours did you have that document A I dont know where this document came from so I cant possibly say this document was on any computer that I may have had access to On a personal computer of your own did you have lists of the phone numbers and contact information relating to Jeffrey Epstein A Like everybody I have an address book but I cant possibly testify to where this thing came from Was it your address book or was it addresses that related to Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A I dont know what youre asking me On your personal computer the address book you are referencing was it your Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential address book with individuals you knew or was it an address book for your employer Jeffrey Epstein A Jeffrey has his situation and I have no this is Jeffreys it came from his home so I cant testify to anything about this in that period of time So you didnt have on your computer a list of contact information for individuals that was related to Jeffrey Epstein A I dont recall exactly what I had back in and so I cant say what I had back then that relates to his addresses I cant recall So is it possible that someone could have downloaded from your personal computer a list of names and address that were affiliated with Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A This didnt come from any computer of mine But is it possible that someone could have downloaded a list of names and Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential addresses affiliated with Jeffrey Epstein from your computer MR PAGLIUCA Objection to the form and foundation A I already said I didnt have a computer there so I dont know where this came from I have no idea Im going to read to you some testimony from deposition and its on page and I want to ask you a question about it if its true or false MR PAGLIUCA Im going to object unless you show the witness the document MS McCAWLEY I will pass it We are not going to mark it We will skip it Did you ever tell that he better watch out and better keep his mouth shut with respect to what occurred at Mr Epsteins home MR PAGLIUCA Objection to the form and foundation A It doesnt sound like anything I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential would say Did you ever threaten in any way if he were to disclose information he learned from his employment with Jeffrey Epstein MR PAGLIUCA Objection to the form and foundation A Im happy to answer No I never threatened him in any way Were you concerned that he was going to disclose that Jeffrey Epstein was trafficking underage girls MR PAGLIUCA Objection to the form and foundation A First of all there are so many things wrong with that question but I have no knowledge of what you are talking about Have you ever contacted or instructed anyone to contact any witness in this case for the purposes of threatening them not to testify in this case MR PAGLIUCA Objection to the form and foundation A I have never called anybody with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential reference to this case with any anything you just mentioned I never threatened anyone Have you ever directed anyone to call any witnesses relevant to this case and threaten them not to testify MR PAGLIUCA Objection to the form and foundation A I never done such a thing Did Jeffrey Epstein or you ever ask any female regardless of age to carry Jeffreys baby for him MR PAGLIUCA Objection to the form and foundation Or anything along those lines MR PAGLIUCA Objection to the form and foundation A Can you repeat the question please Did you or Jeffrey Epstein ever ask any female regardless of age to carry Jeffrey Epsteins baby for him MR PAGLIUCA Objection to the form and foundation A Are you asking Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential To become pregnant did you or Jeffrey Epstein ever ask any female to become pregnant and carry Jeffrey Epsteins baby for you or for Jeffrey MR PAGLIUCA Objection to form and foundation A You need to be very specific I have no idea what you are talking about Thats completely rubbish Did you or Jeffrey Epstein ask any female to become pregnant and carry his baby for either him or you MR PAGLIUCA Objection to the form and foundation Go ahead A I cant testify to anything Jeffrey did or didnt do when I am not present but I have never asked anybody to carry a baby for me Or anything along those lines MR PAGLIUCA Object to the form and foundation I want to make sure we are talking about the same thing not physically carry a baby I mean become pregnant with a baby Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation I want to make sure we are clear A I dont know what you are asking Thats why I want to make sure we are clear A We are clear I never asked anybody to carry a baby for me Do you know if Jeffrey ever asked anybody to carry a baby for him A Im not going to characterize any conversation Jeffrey had with somebody else You are not aware of that is that your testimony A I am testifying I never have and I will not testify for anything for Jeffrey Did you ever hear Jeffrey ask anybody to carry a baby for him A I dont recollect conversation about Jeffrey and babies in any form Did Jeffrey ever tell he wanted to have a baby A I dont recollect baby conversations with Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential So he never told you he wanted to have a baby A I dont recollect any baby conversations with him saying he wanted to have a baby Did you ever bring any females to the house that were not your friends children that were under the age of MR PAGLIUCA Objection to form and foundation A I have never to my knowledge brought anybody under the age of thats not a friend of my family or my nieces or nephews to the household Earlier today you testified I believe that with respect to your town home Jeffrey paid for some of that and then gave you a loan is that correct MR PAGLIUCA Objection to the form and foundation A I said actually I think it was a loan I believe it was a loan The whole thing A As best as I can recollect Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you pay that loan back A I dont have any outstanding loans with him So you paid it back A I dont have any outstanding loans with him Thats not an answer to my question Did you pay back Jeffrey for the loans A I have paid back any loans I had with him You have or havent A Have Were there any other gifts that Jeffrey gave you during the time period of say to the present that were in excess of MR PAGLIUCA Objection to the form and foundation A Whats the question again Did Jeffrey give you any gifts in excess of amounts of Im not talking about a scarf here or something Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential insignificant from to the present A I cant recollect any gifts Did he ever buy you a car A I really dont recall I cant recall its a long time ago You cant recall if Jeffrey Epstein ever bought you a car A I believe he did buy me a car I dont recall how much it cost I dont recall any of the financial details of that Do you still have that car A I dont How long ago did you get rid of that car A I dont recall all the cars There was a car back there was I dont recall Im sorry He supplied you with several cars MR PAGLIUCA Object to the form and the mischaracterization of the testimony A I dont recall details of the cars Did he supply with you more than one car Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Over the course of time Ive driven many cars That Jeffrey provided to you A They were cars that could be driven and I just dont recall them Were they in your name A I dont recall You dont recall if Jeffrey Epstein ever put a car in your name A We are talking a long time ago I really dont recall When is the last time you had a car from Jeffrey Epstein that you used A Do you recall what kind of a car that was A I dont recall Im sorry Did Jeffrey Epstein purchase anything else for you besides the townhouse and cars that would be over the amount of A I didnt say that he did I said I had a loan Besides the loan Im sorry you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential are right you did say you had a loan and you said you paid that back correct A Thats my testimony Anything else in excess of that he would have purchased for you A We are talking I dont recall any gifts really When is the last time Jeffrey Epstein gave you a gift in excess of MR PAGLIUCA Assumes facts not in evidence Form and foundation Youre saying you dont remember from and Im asking when is the last time you remember Jeffrey Epstein purchasing a gift for you A I dont recall gifts in excess of I barely recall gifts I barely recall a lot of this Im sorry I dont recall Is Jeffrey Epstein paying for your legal fees in this case A No Is he paying for anything related to this case Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No Are you aware of any grand theft police report relating to Virginia Roberts A I believe Ive read a report in the press on that Did you provide the press with a report on a grand theft by Virginia Roberts A I dont know how the press got that story Do you know if Virginia Roberts committed a grand theft A I only know what I read in the press Did you ever state to the press that Virginia Roberts committed a grand theft A Ive never had any conversation directly with press Did any of your representatives ever inform the press that Virginia Roberts committed a grand theft MR PAGLIUCA Objection to the form and foundation A I have no way of knowing what my Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential representatives said to press or didnt Did they ever discuss with you the fact that they were going to report that Virginia Roberts participated in a grand theft A I dont know how first of all I dont know how I know that I believe I read it in a press report so Im going to mark this as composite exhibit Maxwell please Maxwell Exhibit email marked for identification Im going to direct you to page GM At the top of that page you are going to see an email address from Jeffrey Epstein on Sunday June to A Yes The re line says This is the actual version they wanted me to send which I changed but this is back from my U.K lawyers Do you see that A Yes Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential If you go down further youre going to see halfway through the page you will see your email address the and you will see a statement that says Thank you I have it now Im working on the letter a little I will send final version tomorrow and whatever is in it will be factually accurate Beneath that you will see who I believe you identified earlier as one of your attorneys A Uh-huh And you will see a letter starting the text of a letter starting I want you to turn to the second page which is GM About halfway through the page it says you will also presumably draw attention to the fact that prior to filing her suit against Mr Epstein Ms Roberts fled the U.S to avoid being arrested for grand theft Police report available What grand theft were you referring to there that Virginia Roberts committed MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I dont know However I believe she stole money from somewhere where she worked How do you know that was grand theft A I dont know how I know that So you authorized a statement that characterized that as grand theft without knowing whether it was grand theft A What month what is the date of this The date of this is June A So Im afraid such a long time ago Im not sure how I really couldnt testify as to how that language ended up in here Do you have the police report It says police report available Do you have that document A I dont have that document Who does A I have no idea Would your lawyer have that document Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont know who has this document Whats your basis in that statement for saying Ms Roberts fled the U.S A Again you are asking me for a statement that I made in and I cant say what in exactly the basis of that statement was So you dont know whether or not that statement is true A This is in and it never went out so Im not sure exactly But you said in your email that you were working to make it factually accurate is that correct A Thats what it says Im going to mark as Maxwell a document dated February Maxwell Exhibit email marked for identification This is an email from who youve identified as your on February to which I understand to be your email address and The subject line says VR cried rape Prior Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential case dismissed as prosecutors found her not credible The message says Ghislaine some helpful leakage dot dot dot What is it you were leaking to the press MR PAGLIUCA Objection there is no foundation that she leaked anything and you know that What was it that you were leaking to the press in that statement A Again I dont think thats referring to that thats just referring to the press getting hold of whatever story it is What was leaking to the press MR PAGLIUCA Objection to form and foundation A It doesnt say was leaking anything It doesnt say that The statement says helpful leakage is that correct A It says helpful leakage That doesnt mean he leaked anything Did you leak to the press Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential information to the press information about the subject line VR cried rape prior case dismissed as prosecutors found her not credible A I dont no idea what is referring to I think he is referring to the press held the story I couldnt testify to that Did you leak to the press information regarding the statement VR cried rape prior case dismissed as prosecutors found her not credible either through you or through A I think this is coming from the daily mail That is not my question Im asking whether you or leaked that A I have no knowledge I have no idea Im sorry I cant I have no recollection I have no idea what she is talking about Im going to mark this as Maxwell Exhibit email marked for identification Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential This is an email addressed at the top from Jeffrey Epstein on Monday January to which I understand to be your email address The email reads You can issue a reward to any of Virginias friends aquaints family that come forward to help prove her allegations are false The strongest is the dinner and the new version of the Virgin Islands that practiced in an underage orgy Did you offer any rewards to Virginias family or friends to contradict Virginias story A Absolutely not Did Jeffrey Epstein offer any rewards to any of Virginias as he suggests here friends family or acquaintances to contradict Virginias story MR PAGLIUCA Objection to the form and foundation A I have no idea what he did Did he tell he was going to offer rewards to Virginias acquaintances friends and family to prove her allegations were Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential false A He did not Do you know whether Jeffrey Epstein paid to give testimony about Virginia Roberts A I dont know who is So you dont know whether Jeffrey Epstein paid her A I dont know who is Have you ever contacted any of Virginias friends acquaintances or family regarding this case A I dont know who Virginias friends or family are and I have not contacted anybody related to her in any way shape or form I will turn you I believe its the thicker document which is Maxwell I believe it was right there the compilation document to GM at the bottom GM You actually may want to turn to the prior page so you can see the email chain At the top of the page MR PAGLIUCA I dont have a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential on mine MS McCAWLEY Its the second page in that document MR PAGLIUCA Okay Its dated Friday March from Maxwell to Jeffrey with the title Daily Mail and there is a forward from to you and a number of other individuals thats on the cover page and as you scroll to the second page you are going to see that part of the chain that Im asking about and that is the chain at the bottom which is dated from and it says we think we should think about the letter to the editor School can be university Age of consent in Florida is complex See below if you are years old a sexual relationship with someone between and is legal in Florida Two persons between and Florida statute A person years or of age or older who engages in sexual activity with a person or years of age commits a felony in the second degree So as soon as you turn you are able to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential have sexual relations and you can have sexual relations with a minor under the age of until your 24th birthday Why were you concerned with the age of consent in Florida MR PAGLIUCA Objection to the form and foundation of the question A I wasnt concerned I think this was somebody sending me the statute for informational purposes Who is A He is the person who boss I believe I dont know what the relationship is I didnt hear you A I Im not sure exactly Why would he be sending you information addressing concerns about the age of consent in Florida MR PAGLIUCA Objection to the form and foundation A I think he was just trying to be telling me details that would happen Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Virginia in was claiming she was and we thought she was I didnt know what the statutes were in Florida and I think he was just trying to be helpful so I would know Did you have a concern that you had violated this statute in Florida MR PAGLIUCA Objection to the form and foundation A No Did you have a concern that Jeffrey Epstein had violated this statute in Florida A Im not concerned what happened with Jeffrey Im only concerned what happens with me Why did you communicate with about the sexual consent age in Florida MR PAGLIUCA Objection to the form and foundation It misstates her testimony A I wasnt concerned I think he was being helpful and stating what the statute was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im going to turn you now in that same stack the Bates number GM At the top of the email you are going to see Jeffrey Epstein dated June to you and its got a re line Vanity Fair If you go down the chain you will see where it says under your email Do you have a problem with anything I said Were you communicating with Jeffrey to confirm what statements you could put in any press releases you were given MR PAGLIUCA Objection to the form and foundation A Any interest I have is in accuracy Were you confirming with Jeffrey Epstein what information you could put in press releases MR PAGLIUCA Objection to the form and foundation A Again Im only looking for accuracy Why would you ask him if he had a problem with anything you were saying A If there is anything I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential characterized that was not correct Thats not what you said You said do you have a problem with anything I said MR PAGLIUCA Objection to the form and foundation There is no question pending MS McCAWLEY There is MR PAGLIUCA Thats not a question its a statement MS McCAWLEY Dont interrupt me Di you say do you have a problem with anything I said A That was asking in my parlance that I wanted him to check it for accuracy Did he tell you there was anything inaccurate about the statement A Again I have to read the whole thing to figure that out Were you coordinating with Jeffrey Epstein during this time period in regarding statements that you were issuing to the press MR PAGLIUCA Did you withdraw the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential last question MS McCAWLEY Im not withdrawing anything Im asking a question MR PAGLIUCA There was a question pending You didnt let the witness answer the question then you moved on to another question so Im asking for clarification for the record now which question are we answering MS McCAWLEY There is an answer The question was did he tell you anything there was anything in the statement inaccurate about the statement and she said again I read the whole thing THE WITNESS I would have to MS McCAWLELY I would have to read the whole thing to figure that out MR PAGLIUCA Then she started reading it and you asked another question MS McCAWLEY Thats the question MR PAGLIUCA Im wondering if its still pending Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MS McCAWLEY It was answered Were you coordinating with Jeffrey Epstein during the time period in regarding the statements you were issuing to the press MR PAGLIUCA Objection to the form and foundation A I only wanted to be accurate in any factual statements that I made You knew at that time that Jeffrey Epstein had been convicted for sexual abuse of a minor is that correct MR PAGLIUCA Objection to form and foundation A He was sentenced I believe for underage soliciting an underaged prostitute You knew that he was a registered sex offender A Yes You were coordinating with him the statement that you were going to be making to the press to confirm whether they were accurate in your words Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I was not coordinating with Jeffrey He had details that I did not have I was not party to his case I needed to have information in order to be able to respond so I was not coordinating with him I was merely asking for details that I could have Did Jeffrey write any of your press statements for you A No He didnt draft any of them A I have a lawyer who was working on this and that was I asked I believe as I recollect asked him for information to make sure I was being accurate in the representations for whatever I was discussing Did Jeffrey provide you with any drafts of statements to provide to the press A I only recall drafts from my lawyer I will mark this as Maxwell Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Maxwell Exhibit email marked for identification This is an email from you on January to The statement you had before you earlier that if you can pull that in front of you the one page press release that you gave You might know from memory Was the press release that you issued with the statement about Virginia issued in or around January A As best as I can recollect I want to turn your attention to the document I just handed you which is Bates No from you to It says in the first sentence Im out of my depth to understand defamation other legal hazards and I dont want to end up in a lawsuit aimed at me from anyone if I can help it Apparently even saying Virginia is a liar has hazards You knew at the time you called Virginia a liar in early January of that that was something that would result in a Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential lawsuit is that correct MR PAGLIUCA Objection to the form and foundation A I have legal advice that I took But you knew in early January by making a statement calling Virginia a liar that you were subjecting yourself to a legal dispute with her MR PAGLIUCA Objection to the form and foundation A I took legal advice as to what should be said and not be said and the legal advice that came from the United Kingdom was MR PAGLIUCA You are not allowed to talk about any legal advice that you got from anybody thats a lawyer A Sorry So is it correct without telling me what you talked to your lawyers about that you knew because this is dated January that when you made this statement in early January January of you knew that calling Virginia a liar would subject you to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential a legal action isnt that correct MR PAGLIUCA Objection to the form and foundation As to what you knew whatever she knows would be privileged MS McCAWLEY Im asking if she knows Im not asking her to tell me about her privileged communications A All I can say is I asked a question and received legal advice Maxwell Exhibit email marked for identification This is an email dated January from Jeffrey Epstein to you A Uh-huh It states in the first line do you want to come out and say she was the girlfriend during the time MR PAGLIUCA Objection to the form and foundation of the question and actually the word is there is no vowel in there MS McCAWLEY I was just trying to pronounce it Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential This email reads do you want without a vowel to come out and say she was the girlfriend during the time Who was Jeffrey Epstein referring to A I believe he was referring to Why was he asking you if you wanted to come out and say she was the girlfriend MR PAGLIUCA Objection to the form and foundation A The way the press and you were characterizing me is I was with Jeffrey throughout this entire period of time and I was not Was with Jeffrey during this period of time A I believe she was Did Jeffrey come out and tell the press it was and not you that was with him as he is proposing here A I dont believe he did Did you want him to do that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A No I didnt ask him to do anything No So do you know in January of was his girlfriend A I have no idea who was his girlfriend in Im sorry you are correct In the period of to was his girlfriend A They spent a lot of time together Did you talk to about going to the press and saying that she was the girlfriend and not you A I have never spoken to Was offered any money to make a statement that she was the girlfriend MR PAGLIUCA Objection to the form and foundation A I have no idea I have never spoken to and I dont know anything I have no idea Maxwell Exhibit email marked for identification Thats an email from Jeffrey to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Maxwell dated January A Uh-huh I will direct your attention to the bottom email which is from you on Saturday January It says I would appreciate it if would come out and say she was your girlfriend I think she was from the end of to Does that refresh your recollection that you asked Jeffrey to have come out and say she was his girlfriend A Im sure I would loved anybody to come out and say they were with Jeffrey rather than me Was that an accurate statement you were asking to be made to the press MR PAGLIUCA Objection to the form and foundation A When is this The statement is whether she was the girlfriend from to As the email reads A What is your question My question is was that an Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential accurate statement you were going to be giving to the press A I didnt make the statement and never came out so its completely moot My question is was it an accurate statement that was the girlfriend from to or were you just making that up for purposes of deflecting press from you MR PAGLIUCA Objection to the form and foundation A As I said they spent a lot of time together and Were you also his girlfriend from to A I dont if I would have ever characterized myself as his girlfriend but at that time was with him as much if not more than I was I will mark this as Maxwell Maxwell Exhibit email marked for identification This is an email at the top its Bates labled At the top is a chain Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential from Jeffrey to you on January and if you look below Im going to start at the bottom of that chain which is January at from Jeffrey and he wrote do you have an article coming out in Mondays paper If so could you please forward us a copy Do you know what Jeffrey was referring to there A I dont know If you look up in the email chain do you see an email address from responding to that letter A I do So that would be that Jeffrey was emailing at that time according to this chain correct A It certainly looks like it The email from to Jeffrey is Nothing on Monday Im working on several possible articles about unfairness in the legal process that allows false charges to be inserted into legal documents with no opportunity to respond And do you see above that Jeffreys Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential email to you says quote Careful A Is that to me or to Jeffrey to at the top Why was Jeffrey telling you to be careful MR PAGLIUCA Objection to the form and foundation A I have no idea What was he concerned about with suggestion in the email below MR PAGLIUCA Objection to form and foundation A I cant possibly know Did you discuss with him why he told you to be careful A I had limited contact with him I dont recall where this goes in the chain why he was telling me to be careful I have no idea Did you respond to this email A If you dont have it I didnt respond Did you ever delete emails during the period of January of Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have every email that you asked for in discovery that I have I gave you Thats not my question Did you ever delete emails in January of A I have not deleted anything that you have asked me for in discovery I have given you everything that I have That is not my question my question is did you ever delete emails in January of A In the normal course of my work there are emails from spam that I delete That is the type of email Ive deleted Anything that is material to what you want I have not deleted How do you know that A Well anybody thats to do with Jeffrey or or women or anything of which I know you were interested in of which I have anything I would not have done because I dont want to subject myself to Have you had your computer forensically copied for purposes of this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential litigation MR PAGLIUCA Objection to the form and foundation A Has someone made a copy of your computer for purposes of this litigation A No Are you a citizen of the United States A I am Are you also a citizen of England A I am Are you a citizen of any other land A TerraMar Thats the name of your charity project that deals with oceans is that correct A Yeah Im French as well Has Jeffrey Epstein funded TerraMar for you A He did give some money to TerraMar yes How much A I believe it was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Earlier today you said you were in the process of resolving the sale of your town home Where do you intend to live once your town home is sold A Thats a good question I dont have an answer for you yet You dont have a present plan Do you intend to live in the United States A I dont have a present plan Are you living outside of your town home right now or are you still there A Im just couch surfing Has Jeffrey Epstein ever purchased a company for you or put a company in your name MR PAGLIUCA Objection to the form and foundation A I have no recollection Is there a Ghislaine Maxwell corporation for example A No not that I am aware of that has anything to do with me There may be with one that someone else owns or started but not one that is related to me Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MS McCAWLEY Im going to take a short break and make sure to keep it short because I know you wanted to I just want to wrap up what we have left THE VIDEOGRAPHER Its now we are off the record Recess THE VIDEOGRAPHER Its now p.m and we are back on the record Ms Maxwell do you recall being subpoenaed for a deposition back in A I do Why did you avoid giving your deposition in that case when you were subpoenaed and had the opportunity to tell your side of the story MR PAGLIUCA Objection to the form and foundation A Thats not what happened What happened A As I best recall I was subpoenaed and a date was set for the subpoena and everything was set and I believe it was with Brad Edwards correct me if Im wrong and Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Brad Edwards failed to show up for the subpoena So your testimony is Brad Edwards did not show up for the deposition that had been set A Correct Did you give any statement that your mother was ill and therefore you couldnt take your deposition and had to leave the country indefinitely A Thats an entirely separate situation Brad Edwards was involved in the I believe you know is when fake suits were created in Jeffreys case and and Brad Edwards worked for that firm And Mr Edwards worked for that firm A So when the subpoena came Brad Edwards was involved with in the case so when I was called for subpoena then and I had a subpoena date and time set Brad Edwards went AWAL meaning he failed to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential respond to calls and failed to get in touch with my attorneys even though a date and time was set for the subpoena and so thats what happened to that subpoena It just didnt happen We may be talking about two different cases so I will ask the question again Was there ever a time where you were subpoenaed to sit for a deposition that you could not make it because you said that your mother was ill A So that is the same subpoena that Brad Edwards failed to turn up for and then I think five or six months passed between a period of time I cant characterize it exactly a period of time passed where then he resurfaced and asked for a new subpoena to be a new time to be set and because he had contacted the press and done all sorts of things that you guys are familiar with I believe it was my lawyer suggested that I should have some sort of protective order and I believe between the time for when Brad Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Edwards resurfaced after the for creating fake cases in Jeffreys and other peoples cases in between the time when there were trying to figure out the protective situation for me my mother was sick she is she was at that time so I they we can all we all have parents so anyone I dont know how old your parents are but any parent or godparent any individual who is in the late we can understand has health issues so my mothers health was deteriorating very rapidly at that time and we had issues at home with who she would talk to and how to manage her her healthcare situation and so I went home They were still arguing about the protective order Is it your testimony that there was not a date set for your deposition at the time you left to go see your mother A I dont believe so Are you friends with the A I am Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you attend a wedding of a few weeks after the date was set lets say a few weeks after you left to go see your mother who was ill A I dont recall exactly when I left but it was before a few weeks before I dont remember the exact timing of that so Im sorry can you repeat the question Did you come back to the United States to attend wedding A I attended wedding but I dont know if I came back specifically for that or not When we were looking at the flight logs earlier there was a flight where you ended up in I believe it was in do you know how you got clearance to land at that A I need to have a look at whatever document Its one of the flight logs it was on the flight with when we were talking about you landed at I know you are a pilot do you know what you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential had to do to get clearance to land at that naval base MR PAGLIUCA If you need to look at something to answer the question you can If you cant answer the question without looking at something just indicate such A Regardless I wouldnt have any knowledge of that Was traveling with you on the flights you were on with A I would have to look at a document I wouldnt know if she was on all of them or not I dont know Do you recall her being on any of them A To the best of my recollection I think she was I dont recollect exactly what flight she was on or not was one of the co-conspirators physically in the nonconstitution agreement is that correct MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I have never seen the document but my understanding I believe is that she was Did you ever stay the night ever at house have you ever stayed the night there A In his home Yes A I dont believe I did Are you aware of anybody providing Jeffrey with two year old girls as a birthday present MR PAGLIUCA Objection to the form and foundation A No Are you aware of anybody ever providing Jeffrey with French girls under the age of as a birthday present MR PAGLIUCA Objection to the form and foundation A No Do you know whether provided girls under the age of to Jeffrey for the purposes of sex MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I am un the answer is no I dont know anything about that Did you ever witness bringing girls under the age of to any of Jeffrey residences MR PAGLIUCA Objection to the form and foundation A I dont recollect coming to the house with girls period Do you when I say house Im including the U.S Virgin Island home Do you recollect bringing foreign girls under the age of to the U.S Virgin Island house A I dont recollect anything like that Do you know how Jeffrey Epstein made his money A No Was one of his clients A I have no idea What do you know about the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential relationship between Jeffrey Epstein and A Are you talking today Yes today A I have no idea Do they have a business relationship A I have no idea Did they have a business relationship during the time that you were working for Jeffrey Epstein A I believe in the when I was there they had a business relationship Did they have any other kind of relationship MR PAGLIUCA Objection to form and foundation A The only relationship I am aware of is the business relationship Do you know why sold the New York house or gave the New York house to Jeffrey if you know MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I know nothing about that transaction Can you list for me all the girls that you have met and brought to Jeffrey Epsteins house that were under the age of MR PAGLIUCA Objection to the form and foundation A I could only recall my family members that were there and I could not make a list of anyone else because that list it never happened that I can think of Im talking about the time you were working for Jeffrey Epstein can you list all girls that you found for Jeffrey Epstein that were under the age of to come work for him in any capacity MR PAGLIUCA Objection to the form and foundation A I didnt find the girls You choose the word MR PAGLIUCA If you have a question ask it you dont choose the word Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential List all of the girls you met and brought to Jeffrey Epsteins home for the purposes of employment that were under the age of MR PAGLIUCA Objection to the form and foundation A Ive already characterized my job was to find people adults professional people to do the jobs I listed before pool person secretary house person chef pilot architect Im asking about individuals under the age of not adult persons people under the age of A I looked for people or tried to find people to fill professional jobs in professional situations So Virginia Roberts was under the age of correct A I think weve established that Virginia was Is she the sorry go ahead Is she the only individual that you met for purposes of hiring someone for Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Jeffrey that was under the age of MR PAGLIUCA Objection to form and foundation Mischaracterizes her testimony A I didnt hire people I said met A I interviewed people for jobs for professional things and I am not aware of anyone aside from now Virginia who clearly was a masseuse aged but thats at least thats how far we know that I can think of that fulfilled any professional capacity for Jeffrey List all the people under the age of that you interacted with at any of Jeffreys properties A Im not aware of anybody that I interacted with other than obviously Virginia who was at this point Maxwell Exhibit email marked for identification Im showing you whats been marked as Maxwell its an email dated January from Jeffrey to you Is that you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential can take a moment to take a look at it is that a statement that Jeffrey Epstein wrote for you to be issued to the press MR PAGLIUCA Objection to the form and foundation A The question was Is this a statement that Jeffrey Epstein wrote for you to be issued to the press MR PAGLIUCA Same objection A Is there any other emails that you have that surround this that would allow me to know what does this have a context These were produced by your counsel so the to extent there are emails that surround this this is what we were given A Okay I dont know whether he wrote this obviously he wrote this and sent this to me I dont know if this is post a phone call we had I cant recollect exactly Do you know if this was issued to the press this statement A The only press statement that was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential issued is the one that you have When the paragraph refers to you being in a very long term committed relationship with another man who was that other man MR PAGLIUCA You dont have to answer the question MS McCAWLEY Im asking the identity of a witness in a statement she is giving MR PAGLIUCA She didnt give the statement MS McCAWLEY Jeffrey is writing to her Im asking who is he is referencing to a long term relationship You are going to refuse to let her answer that question MR PAGLIUCA Yes MS McCAWLEY I would like to state for the record he is refusing to allow her to identify a potential witness in this litigation So we will be back to get the answer to that question Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you recall when you were traveling with Virginia Roberts that you would be responsible for holding her passport MR PAGLIUCA Objection to the form and foundation A I already testified I dont recall traveling with Virginia Do you recall whether Jeffrey Epstein when he was traveling with a minor someone under the age of someone would hold their passport MR PAGLIUCA Object to the form A I couldnt testify to what Jeffrey did or didnt do You never observed him gathering a minors passport and holding it during one of the trips you were on A I dont have a recollection of that Are you familiar with a company called Hyperion Air Inc A I am Is that a company you are Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential affiliated with A No Is that a company that Jeffrey owns A I knew it back in back when I was working I have no idea what that is today What about JEGE are you familiar with that company JEGE Inc A I dont recall it You dont recall A It vaguely rings a bell I dont remember what it relates to What about Epstein Virgin Islands Foundation Inc Are you familiar with that company A No How did Epstein Company Inc A Again I dont recall his business names and affiliations How about NES LLC are you familiar with that name A Again I think that was one of his businesses but I dont recall Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Do you know what that business did A I dont How about New York Strategy Group Inc A I dont know What about Ghislaine Maxwell Company are you familiar with that company A I never heard of that Is that a company you are on record as being either a board member of or having a position of authority in MR PAGLIUCA Objection to the form and foundation A Ive never heard of the business What negative unflattering private or potentially embarrassing information does Jeffrey Epstein know about you MR PAGLIUCA Objection to the form and foundation A I imagine none Does he know does he have any knowledge of any illegal activity that youve conducted Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation A If you want to ask Jeffrey questions about me you would have to ask him Have you ever been involved in any illegal activity in your lifetime MR PAGLIUCA Objection to the form and foundation A I cant think of anything I have done that is illegal Have you ever been arrested A I have a DUI in the U.K a long time ago Is that the only arrest you have on your record A Yes I will mark as Maxwell this email Maxwell Exhibit email marked for identification This is dated January Its from Jeffrey Epstein to you forwarding the Guardian and I would like you to look at Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential the chain of emails so you understand the have an appreciation for who is on this Its a three-page document The bottom of the email appears to be a message from there is a at the very bottom there is the signature block for and above that there is a message from a Do you see that A Uh-huh Do you know who is A I do not Above that there is a message from and you and it says so this isnt getting better latest from our chums at the Guardian and above that you will see on January an email from you where you wrote See below And right above that chain you will see Jeffrey Epstein to you on January and his statement to you is This will now end but I think a dismissive statement is okay What did he mean by his statement Case Document Filed Page of I MAGNA9 LEGAL SERVICES Page Maxwell Confidential This will now end MR PAGLIUCA Objection to the form and foundation A I have no idea Did you discuss with him what he meant by the statement This will now end A I dont recall Was he taking any action to ensure that quote this will now end A I have no idea Maxwell Exhibit email marked for identification This is an email from if you look at the chain at the top you will see its from you to Jeffrey on January and the email at the bottom of the chain is from Jeffrey to you on January He states What happened to you and your statement question mark question mark And you put at the top I have not decided what to do A Uh-huh Why was Jeffrey interested in you making a statement to the press Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I dont know that he was interested We made a statement and then I was being advised to make an additional statement and I never did Was Jeffrey communicating with you regularly on what additional statement you might make MR PAGLIUCA Objection to the form and foundation A No Ive communicated with him very little as little as possible Why did you feel you had to keep him informed of statements you were making to the press MR PAGLIUCA Objection to the form and foundation A I didnt feel I had to Then why you were communicating with him about statements you were making to the press MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Insofar as this is the case its really all about Jeffrey its not a case about me In did you direct your lawyer either directly or indirectly to tell Brad Edwards that you were unavailable to attend a deposition MR PAGLIUCA Objection to the form and foundation And this is a privileged communication as I understand the question what someone said or didnt say to their lawyer So dont answer the question Can you answer that question without revealing a privileged communication A Can you ask the question again In did you direct your lawyer to tell Brad Edwards that you were unavailable to attend a deposition MR PAGLIUCA Same instruction Did you make any statement in to anybody that you were unavailable to attend a deposition A My mother was sick and I dont Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential recall exactly the sequence of events but what sequence of events do exist are was handled by my lawyers What is your understanding of Jeffrey Epsteins nonprosecution agreement A I have no idea Do you have an understanding of the co-conspirators listed in the nonprosecution agreement MR PAGLIUCA Objection to the form and foundation A I have no knowledge of his agreement whatever that is Do you know you mentioned earlier today that was one of the listed co-conspirators Do you know who the other co-conspirators are in the nonprosecution agreement MR PAGLIUCA Objection to the form and foundation A I do not know What did Jeffrey Epstein tell you about the nonprosecution agreement Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A I dont think Ive ever discussed it with him How did you come to learn that was covered by the nonprosecution agreement A I believe I read it in the press Did you have any discussions with with about the nonprosecution agreement A I have not had any discussions with When is the last time you spoke to A Maybe maybe And same with when is the last time you recall speaking with A Probably even more time before that maybe Ive never had communications really with Im sorry I didnt hear that A I never had communications with her You were working for Jeffrey at the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential same time was also working for Jeffrey isnt that correct A I didnt know what did for Jeffrey so I didnt characterize what her relationship or work or not was and I was still helping him with his construction projects and the like but I never crossed paths with What did you think was doing for Jeffrey A I have no idea what was doing for Jeffrey Did you observe at any of Jeffreys houses while you were there A She was at the house on occasion What would she be doing there A I have no idea Did you know if she lived at his houses A I have no idea Did you ever go into a bedroom and see her belongings at one of the houses A Not that I recall no Im going to mark this as Maxwell Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Exhibit Maxwell Exhibit email marked for identification You can see at the top of the first page which is GM its dated January from you to the Is that who we referred to today A Yes And can you tell me it says Have some info Call me when you have a moment What is redacted there A I dont recall Im sorry Do you know why there is a redaction on this document A You would have to confer with my lawyers What did you discuss on that call A I dont have any specific knowledge of that call So the call is being made on Saturday January MR PAGLIUCA Objection to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential The document states its Saturday January You issued your press release on January Were you discussing with the subject of Virginia Roberts during these calls MR PAGLIUCA Objection to the form and foundation A I dont know if I spoke to him I would like you to turn to GM and the bottom chain says Saturday January to re and he says let me know when we can talk Got some specific questions to ask you about Virginia Roberts Do you recall having a conversation with about Virginia Roberts in or around early January of A I dont know if we actually spoke Did you ever speak to about Virginia Roberts after you issued your statement on January A I know that we did speak at some point but I dont recollect when we spoke Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential What did you talk about A Just what a liar she is What did he say to you A What a liar she is Did he tell you why he thought she was a liar A I dont think he told me why she was a liar The substance of everything that she said was a lie with regard to him What did you say to him A She is a liar That was the whole conversation it was you said to him she is a liar and he said to you she say liar and did you discuss any of the details about what those lies were A I dont recollect Was that only one conversation you had A I dont recollect I dont recollect actually the conversation but other than in detail other than we both said she was a liar Do you regularly communicate with Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A What do you mean by regularly Do you email with him once a month once every two months or text him or call him A No we are not in that type of regular touch Do you travel with him regularly A I dont know I have traveled with him We have traveled together but regularly is not a correct characterization Do you travel with him more than once a year A There is no standard There is no set pattern The answer to that was no Have you ever observed him with any underage any women female under the age of interacting thats not a child or a family friend interacting for the purposes of a sexual relationship with that individual MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A Ive never seen interact in any way of that nature Have you ever gone to dinner with him with any individual under the age of thats not a family member or friend of yours that is under the age of MR PAGLIUCA Objection to form and foundation A Weve been to dinner all the time I am not not sure who is at dinner with us I cant testify to that Has he ever brought a female under the age thats not a relative of his A He has children I said not relatives A I cant possibly testify to who he comes to dinner with I wouldnt recall To your knowledge has he ever had a relationship with any female under the age of for purposes of a romantic relationship to your knowledge A I cant testify to relationship Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential You havent observed that A No Have you talked to about coming to testify at trial in this case A No When was the last time you communicated with A I believe earlier did you say that you when is the last time youve been to his home in A I said you asked me if I stayed the night Im asking you a different question When is the last time you have been to his home in A Roughly the same time in the middle of the sometime mid Not in the years to A Mid Have you ever communicated with any representative of MR PAGLIUCA Objection to the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation A I mean Ive been to his in the mid I would have communicated with people who worked for him Have you communicated with about this case A No Have you ever seen a topless female at any one of Jeffrey Epsteins properties MR PAGLIUCA Objection to the form and foundation Youve asked this question by the way earlier on today A Again I testified that there are people who from time to time in the privacy of a swimming pool have maybe taken a bikini top off or something but its not common and certainly when I was at the house I dont really recollect seeing that kind of activity Have you ever smoked cigarettes A Yes Have you ever smoked cigarettes with Virginia Roberts A I dont recall smoking cigarettes Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential with Virginia Roberts Im marking this as Maxwell Maxwell Exhibit email marked for identification Im showing you what has been marked as Maxwell This is an email dated January at the top Do you see that that from Jeffrey to you A Uh-huh And then below there is an email from to you and ccing on January Do you see that A Uh-huh It says Dear Ghislaine as you know I have been working behind the scenes and this article comes from that It helps but doesnt answer the VR claims I will get the criminal allegations out This shows the MOS will print truth not just a VR voice piece We can only make the truth by making a statement Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential What did he mean when he said I will get the criminal allegations out what was he referring to MR PAGLIUCA Objection to the form and foundation A I have no idea Were there criminal allegations about Virginia that either your lawyer or were leaking to the press MR PAGLIUCA Objection to form and foundation A I have no idea Did you ask him what he meant when he said I will get the criminal allegations out A I dont recollect the conversation Did you direct him to leak to the press criminal allegations about Virginia Roberts A I already testified that I have no knowledge of what you are asking me Were you copied on this email correct A I was Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did Jeffrey Epstein assist in obtaining information about criminal allegations relating to Virginia Roberts MR PAGLIUCA Objection to form and foundation A I have no recollection Did assist in obtaining information regarding criminal allegations of Virginia Roberts MR PAGLIUCA Objection to form and foundation A I have no knowledge of that Did you ever discuss that with A Discuss what Criminal allegations about Virginia Roberts A I dont believe I have Have you ever discussed allegations relating to Do you know if Jeffrey Epstein had any relationship with the U.S government either working for the CIA or the FBI in his lifetime Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Objection to the form and foundation A I have no knowledge of that Do you know if Jeffrey Epstein has any friends that are in the CIA or FBI MR PAGLIUCA Objection to the form and foundation A I have no idea Are you aware of an investigation of Jeffrey Epstein in the early relating to the SEC MR PAGLIUCA Objection to the form and foundation A I have no knowledge of that Are you aware that Jeffrey Epstein has told people that he worked for the government to recover stolen funds MR PAGLIUCA Objection to the form and foundation A I dont recall conversations about that Has he ever told that you he worked for the U.S government A I dont recollect that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential You dont recollect or has he never told you that A I have no knowledge I dont recollect him telling me he worked for the government Does Jeffrey Epstein have any affiliation with the Israeli government MR PAGLIUCA Objection to the form and foundation A I have no knowledge of that Do you know if he ever performed any work for the Israeli government A I have no knowledge of that Have you ever visited Israel with Jeffrey Epstein A Im sorry I dont recollect Youve seen the flight logs that I provided you today Are there during the time you worked for Jeffrey Epstein were there times that you flew on commercial flights rather than Jeffrey Epsteins planes A Yes How often did that occur A Decently Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Were there other flights that you recall flying on with Jeffrey Epstein that were on flights that where was not the pilot A was not always the pilot How many planes did Jeffrey Epstein have during the time you were with him MR PAGLIUCA Objection to the form and foundation A So you need to give me a date range During the time period of through when you left your employment which I think you said was in A So in the he had one plane and at some point in the he had two planes but I cant testify to anything past what happened to his planes after that Do you know what travel agency if any Jeffrey would use when he would send someone for example you or one of his other employees on a flight somewhere Did he use a particular travel agency to make those Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential arrangements A I dont recall Were you ever responsible for making those arrangements for other individuals A I dont recall making flight arrangements Was it a New York travel agent that you would use for those arrangements A Again we are talking years I just dont recall anything to do with travel agents Would Jeffrey Epstein ever fly for example on a commercial flight to meet you in New Mexico MR PAGLIUCA Objection to the form and foundation A I cant testify to that Do you recall a trip where you met in New Mexico A No I dont recall any specific trip no Why would you be sent to New Mexico is there a reason why you would go Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential there in the course of the work you were doing for Jeffrey MR PAGLIUCA Objection to the form and foundation A I was never sent I had a job to do and I would have to go to New Mexico for work Would assist in that project MR PAGLIUCA Objection to the form and foundation A No The project was largely complete largely complete by the end I dont remember the dates exactly but it was largely complete by the Do you know why would be going to New Mexico to meet you MR PAGLIUCA Objection to the form and foundation A I dont know She worked for Jeffrey MR PAGLIUCA I think we are out of time counsel THE VIDEOGRAPHER Its true Case Document Filed Page of MAGNA9 LEGAL SERVICES Page 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 todays proceedings We are off the record at p.m Time noted p.m Case Document Filed Page of MAGNA9 LEGAL SERVICES Page I GHISLAINE MAXWELL PAGE By Ms McCawley I I MAXWELL EXHIBIT PAGE Exhibit police report Exhibit email Exhibit transcript Exhibit photo Exhibit photo Exhibit flight logs Exhibit photo Exhibit photo Exhibit message pad pages Exhibit email Exhibit photo Exhibit documents Exhibit documents Case Document Filed Page of MAGNA9 LEGAL SERVICES Page MAXWELL EXHIBIT PAGE Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Exhibit email Case Document Filed Page of MAGNA9 LEGAL SERVICES Page CERTIFICATE I HEREBY CERTIFY that the witness GHISLAINE MAXWELL was duly sworn by me and that the deposition is a true record of the testimony given by the witness Leslie Fagin Registered Professional Reporter Dated April The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or supervision of the certifying reporter Case Document Filed Page of MAGNA9 LEGAL SERVICES Page ACKNOWLEDGMENT OF DEPONENT I do hereby certify that I have read the foregoing pages and that the same is a correct transcription of the answers given by me to the questions therein propounded except for the corrections or changes in form or substance if any noted in the attached Errata Sheet GHISLAINE MAXWELL DATE Subscribed and sworn to before me this day of My commission expires Notary Public Case Document Filed Page of MAGNA9 LEGAL SERVICES Page A A PAGE LINE CHANGE Case Document Filed Page of MAGNA9 LEGAL SERVICES Case Document Filed Page of Page A affiliated ability address able affiliation aged accessible affiliations affirmatively accosted accuracy afraid age agency accurate agent addressed accurately addresses accusation absolute accused agents addressing acknowledgment ages admissible absolutely acquaintances admitted ago admittedly adult act action ac ivities agree absurd activity abuse acts adults21:17 abused actual agreement advance advice add added ahead abusing accept addendum advised access add i tion add i tional advising aimed MAGNA9 EGAL SERVICES Xm DX 5F 蠁t?v jfu F굃X U?5I MF?ϰ YOp oi Yj 8?F??KWr?H h?Ӷqr zߓ6W7 h6 S?ǵ 1?P4sb fo KڃnbW U8 wB X9 r?o l?ſ aRZ?d 1B g??D p?dtl?B 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