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DOJ Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Giuffre v. Maxwell, No. 1;15-cv-07433 (S.D.N.Y. 2015)
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EXHIBIT Case Document Filed Page of Case Document Filed Page of Page IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO VIRGINIA GIUFFRE Plaintiff against GHISLAINE MAXWELL Defendant Australian Avenue Suite West Palm Beach Florida Friday September a.m p.m I I A VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline West Registered Professional Reporter Notary Public in and for the State of Florida At Large pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause MAGNA LEGAL SERVICES Avenue of the Americas New York New York Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page APPEARANCES On behalf of the Plaintiff THE UNIVERSITY OF UTAH S.J QUINNEY COLLEGE OF LAW South University Street Salt Lake City Utah Phone E-mail Cassellp law.utah.edu By PAUL CASSELL ESQ and BOIES SCHILLER FLEXNER LLP East Las Olas Boulevard Fort Lauderdale Florida Phone E-mail Smccawley bsfllp.com By SIGRID MCCAWLEY ESQ On behalf of the Defendant HADDON MORGAN FOREMAN East 10th Avenue Denver Colorado Phone E-mail Jpagliuca hmflaw.com By JEFFREY PAGLIUCA ESQ On behalf of the Witness Jeffrey Epstein ATTERBURY GOLDBERGER WEISS P.A One Clearlake Centre Suite Australian Avenue South West Palm Beach Florida Phone E-mail Jgoldberger agwpa.com By JACK A GOLDBERGER ESQ and Appearances continued on the next page Page APPEARANCES MARTIN WEINBERG P.C Park Plaza No Boston Massachusetts Phone E-mail Marty martinweinberglaw.com By MARTIN WEINBERG P.C Appearing telephonically ALSO PRESENT RYAN KICK Video Technician DARLINE MARIE WEST Court Stenographer Page I WITNESS PAGE JEFFREY EDWARD EPSTEIN DIRECT EXAMINATION BY MR CASSELL CROSS-EXAMINATION BY MR PAGLIUCA REDIRECT EXAMINATION BY MR CASSELL CERTIFICATE OF OATH REPORTERS CERTIFICATE I I Description Page Plaintiffs Exhibit JE1 Transcript of the deposition of Ms Maxwell taken on April 22nd Plaintiffs Exhibit JE2 Document with titles of books Plaintiffs Exhibit JE3 Photograph depicting Prince Andrew Maxwell and Virginia Plaintiffs Exhibit JE4 E-mail that Jeffrey Epstein sent to Maxwell on January 12th Page Plaintiffs Composite E-mail Jeffrey Exhibit JE5 Epstein received from Ms Maxwell on about July 18th Plaintiffs Exhibit JE6 E-mail string between Jeffrey Epstein and Ms Maxwell on about March 25th Plaintiffs Exhibit JE7 Transcription of a string of e-mails between Jeffrey Epstein and Ms Maxwell in about May of Plaintiffs Exhibit JE8 E-mail that Jeffrey Epstein sent to Maxwell on January 15th Plaintiffs Exhibit JE9 Document on the public record in the case Jane Doe versus United States in the Southern District of Florida a document signed by Gerald Lefcourt and Alan Dershowitz Plaintiffs Exhibit Subpoena in this case JE10 for Jeffrey Epstein to appear at deposition Plaintiffs Exhibit Transcript of Ms JE11 Maxwell taken on July Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page QUESTIONS MARKED BY THE REQUEST OF COUNSEL PAGE/LINES Page lines through Page lines thorugh At the request of Mr Pagliuca Page lines through At the request of Mr Cassell Page Epstein Confidential I VIDEO TECHNICIAN We are now on the record This begins videotape No in the deposition of Jeffrey Epstein in the matter of Giuffre versus Maxwell Today is September 9th The time is a.m This deposition is being taken at North Australian Avenue West Palm Beach Florida The videographer is Ryan Kick The court reporter is Darline West We both represent Magna Legal Services Will counsel and all parties present state their appearance and whom they represent MR CASSELL I can begin My names Paul Cassell and I represent Miss Virginia Giuffre MS MCCAWLEY Sigrid McCawley with Boies Schiller Flexner on behalf of Virginia Giuffre MR PAGLIUCA Jeff Pagliuca appearing on behalf Gwen Maxwell Page Epstein Confidential MR GOLDBERGER And Jack Goldberger on behalf of the witness Jeffrey Epstein And on the phone is MR WEINBERG Martin Weinberg by telephone on behalf of the witness Jeffrey Epstein VIDEO TECHNICIAN Will the court reporter please swear the witness THE COURT REPORTER Okay Sir could you raise your right hand Do you swear to tell the truth the whole truth and nothing but the truth THE WITNESS Yes maam THEREUPON JEFFREY EDWARD EPSTEIN called as a witness on behalf of the Plaintiff herein having been first duly sworn was examined and testified as follows DIRECT EXAMINATION BY MR CASSELL All right Sir you understand that my client is Ms Virginia Roberts Giuffre MR GOLDBERGER Im sorry Mr Cassell Before we start let let me Page Epstein Confidential just discuss something on the record I understand theres a protective order in place on this case concerning confidentiality in this depositions And as I understand the protective order either party can designate the the proceeding as confidential and I understand counsel for Miss Maxwell is going to do that in this case MR PAGLIUCA Thats correct Im designating this deposition as confidential Any other stips MR GOLDBERGER Huh MR PAGLIUCA Any other stips MR GOLDBERGER No Were good for now MR PAGLIUCA Okay BY MR CASSELL All right Sir you understand Im an attorney representing Miss Roberts Virginia Roberts Giuffre A Ive been advised by my counsel to assert my rights under the Fifth Amendment of the United States Constitution as to any and all questions that Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential could result in a waiver of my Constitutional privileges I understand that one of the basic functions of the Fifth Amendment according to the United States Supreme Court is to protect all citizens including even innocent persons who otherwise might be insnared by ambiguous circumstances On the advice of counsel I assert my rights under the Fifth Amendment and respectfully decline to answer your question MR CASSELL Mr Goldberger its your position that having him acknowledge who my client is creates a realistic risk of incrimination MR GOLDBERGER Were not going to debate at this deposition whether the implication of the Fifth Amendment privilege is proper or not proper We are simply asserting the privilege And if that needs to be discussed or litigated somewhere else well be happy to do so so BY MR CASSELL If I refer to Virginia today I want you to understand that Ill be referring to my client Miss Virginia Roberts Giuffre Page Epstein Confidential Is that an acceptable way to proceed today sir A As I stated before in response to my to your earlier question I am asserting my constitutional right not to respond to that question MR GOLDBERGER This would be a good opportunity I think to kind of discuss ground rules for the implication of the Fifth Amendment MR CASSELL All right MR GOLDBERGER as we proceed in this deposition Weve advised you off the record and its not any surprise to anyone that Mr Epstein fully intends to invoke Fifth Amendment privileges to all of your questions We can as we answer your questions and well be happy to answer all your questions we can use the full invocation that we did in response to your first question we can use the invocation that we just did in response to your second question or we simply can say Fifth Amendment with the understanding that the Page Epstein Confidential answer would be edited and and would be the full answer that Mr Epstein gave to the first question Really your choice on that as to how you would like to proceed MR CASSELL Yeah Whatever you think would be the fastest I want to get through this MR GOLDBERGER Okay MR CASSELL And so obviously well be objecting to many of these invocations already MR GOLDBERGER Sure MR CASSELL I think that these are improper invocations but if were going to litigate that elsewhere that certainly is one way to proceed MR GOLDBERGER Okay So is it fair to say weve reached an agreement that if Mr Epstein simply says the Fifth the answer that would be part of the record for any time these proceedings are used anywhere would be the full invocation Mr Epstein used in answer to the first question MR CASSELL Yes And I would at the Page Epstein Confidential I would then raise an objection to the nonresponsive portion of the invocation such as for example a reference to innocent persons It seems to me thats not necessary for him to take the Fifth MR GOLDBERGER Okay MR CASSELL As long as we have your position and our position both stated all the time that that seems like the most expeditious way to proceed MR WEINBERG One other matter a preliminary matter which is that we would reserve our right to particularize a full basis based on the record of this case the record of the CVARC CVRA case representations that have been made by you and Mr Edwards regarding Mr Epstein and his potential criminal liability and your intention to seek to rescind his non-prosecution agreement the admissions taken on the absence of the meaningful Statute of Limitations in terms of our spelling out if the Fifth Amendment is challenged in regards to any response by Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Mr Epstein for instance a response to whether he even recognizes the name of your client in the event you choose to challenge the essential applicability of the long-standing Fifth Amendment privilege MR CASSELL Im going to object to Mr Weinberg defending the deposition in addition to Mr Goldberg My understanding of the rules MR GOLDBERGER Goldberger Its Goldberger MR CASSELL Im sorry I apologize Mr Goldberger It seems to me the standard is one lawyer for one witness And Mr Goldberger is a very capable lawyer so it seems to me Mr Weinberg should not be allowed to participate by making objections MR PAGLIUCA And for the record I have no objection to Mr Epstein simply saying Fifth Amendment in response to any questions and understand that that answer would incorporate all of the first answer that Mr Epstein gave in this deposition Page Epstein Confidential MR GOLDBERGER Thank you BY MR CASSELL Sir youve been deposed many times before true A Fifth You understand the rules regarding the deposition today true A Fifth You have legal counsel here today to provide advice to you should it be necessary at any point true A True Is there anything including any physical conditions or ailments that would prevent you from giving truthful testimony today A Fifth Please state your full name A Jeffrey Edward Epstein Without disclosing where you may have lived in the past where do you currently reside A Fifth What state are you a citizen of A Can you clarify the question Yeah What state do you consider yourself Page Epstein Confidential to be a citizen of A Fifth You understand that the case caption on the subpoena you received is Virginia Giuffre versus Ghislaine Maxwell A Fifth You know the Defendant in this case Ghislaine Maxwell true A Fifth You first met Maxwell in the early isnt that true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Let me make sure I understand Whats the objection to form MR PAGLIUCA The question is vague BY MR CASSELL When did you first meet Ms Maxwell A Fifth Where did you first meet Ms Maxwell A Fifth What were the circumstances surrounding Page Epstein Confidential your first meeting of Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Could you repeat the question BY MR CASSELL What were the circumstances surrounding your first meeting of Maxwell MR PAGLIUCA Same objection THE WITNESS Fifth MR CASSELL And when you say form you believe that the question that I just asked is vague MR PAGLIUCA It is vague I dont understand what circumstances means It lacks foundation in that there hasnt been an establishment of any time or place of meeting of Ms Maxwell or even that he knows Ms Maxwell under the circumstances of this deposition MR CASSELL Right But you understand there is evidence in the record from which I would have a good faith basis for believing that he has in fact met Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Ms Maxwell MR PAGLIUCA Im not going to debate what you have a good faith for believing or not My my objection stands MR CASSELL Im just confused about how there could be a lack of foundation for whether they have met when your client testified under oath that she had interacted with Epstein repeatedly MR PAGLIUCA Thats my objection MR CASSELL All right BY MR CASSELL Just so were clear the the question let me just I may have asked this before but I want to make sure we havent messed messed missed anything What were the circumstances surrounding your first meeting with Maxwell MR PAGLIUCA Same objection Form and foundation THE WITNESS Fifth BY MR CASSELL And whenever I use the term Maxwell today I wanted it to be clear that Im referring to Page Epstein Confidential the Defendant in this action Ghislaine Maxwell Would you consider yourself currently to be the boyfriend of Ms Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever been a boyfriend of Ms Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true that at some point you had an intimate relationship with Miss Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You were in a long-term relationship with Maxwell from the early through through at least true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL How long did your long-term relationship with Maxwell continue MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You are currently in a relationship with Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You currently have a joint defense agreement with Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You currently have a common interest agreement with Maxwell true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL You understand that your interests and Maxwells interests are aligned in this case MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your understanding of Maxwells interest in this case MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your understanding of your interest in this case MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since the start of you have communicated with Maxwell about how she can best respond to allegations made by Virginia MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Without going into the substance of any communications you have had youve communicated with Maxwell since December 30th true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Can I understand what the objection is to form on that particular question MR PAGLIUCA Do you want to have the reporter read it back MR CASSELL I can just give it to you MR PAGLIUCA Sure MR CASSELL Without going into any substance of any communications that you have had you have communicated with Maxwell since December 30th true MR PAGLIUCA Its a leading question Thats a form objection MR CASSELL All right So can we Page Epstein Confidential just MR WEINBERG And I would add a further objection which is to the extent that any conversations which were pursuant to a common interest agreement you would assert the attorney-client privilege as well as the Fifth Amendment MR GOLDBERGER Right So that objection were making as to attorney-client privilege in no way waives the Fifth Amendment privilege that has been raised to the question MR CASSELL Mr Weinberg since youre participating over my objection can you confirm that there is a joint defense agreement between your client and Ms Maxwell MR PAGLIUCA Im going to object to any interrogation of Mr Weinberg Hes not been noticed for a deposition hes not under oath and hes not present here MR CASSELL Im just trying to understand the objection so that I can avoid it in any future questions Page Epstein Confidential What was the nature of your objection regarding common interest and joint defense agreement Mr Weinberg MR WEINBERG It was direct status asserting the attorney-client privilege as well as the Fifth Amendment Im making no representations regarding the existence of any agreement MR CASSELL All right You also objected to my last question based on foundation What was the foundation objection MR PAGLIUCA Theres multiple foundational issues We dont know the source of any information that would be responsive to the question It could contain hearsay and speculation You know all of these questions frankly lack foundation under the circumstances here Frankly I dont believe that there it will be a good faith basis for most of the questions I dont believe that most of these questions will be supported by any independent evidence Page Epstein Confidential This is simply an exercise for you Mr Cassell to use leading questions to try to obtain some adverse inference and advantage in this litigation when you know that this witness is going to blanketly assert a Fifth Amendment privilege Frankly I see no point in actually having this deposition since all of these issues are going to need to be litigated before the court before we can actually have a determination of what Mr Epstein may or may not testify about so MR CASSELL My specific question though is the question I asked Epstein was Without going into the substance of any communications that you have had you have communicated with Maxwell since December 30th Since your client has testified under oath that she did indeed have communications with Epstein since December 30th I cant understand why that question would lack a foundation MR PAGLIUCA Well I Ive made my Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential record It it is lacking in foundation MR CASSELL All right BY MR CASSELL Without going into the substance of any communications that you have had you have communicated with Maxwell since September 21st true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many communications have you had with Ms Maxwell since December 30th A Fifth What methods of communications have you used when talking to Maxwell in the last two years MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What e-mail accounts have you used in your communications with Maxwell MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL What e-mail accounts has Maxwell used in her communications with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your cell phone number sir A Fifth How many cell phones do you have A Fifth Please provide all of the cell phone numbers that you currently have access to A Fifth Please provide all the cell phone numbers that you had access to in and A Fifth Please provide all of the e-mail accounts that you had access to in and A Fifth Please provide all of the e-mail accounts that to your knowledge Ms Maxwell had access to in and Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You are a registered sex offender correct A Fifth In previous depositions you have stated that you are a registered sex offender true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In June in open court you pled guilty to two Florida State felonies correct A Fifth You were sworn to tell the truth in those public proceedings true A Fifth In open court what did you testify that you had done A Fifth And in my previous question Im referring to the plea proceeding that was in about June of Did you understand my question Page Epstein Confidential A Yes In open court what things did you say in that hearing A Fifth Did you tell the truth in that hearing A Fifth Did you tell the court that you accepted responsibility for those crimes A Fifth Were you accepting responsibility for those crimes A Fifth Why were you accepting responsibility for those crimes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did you apologize to the victim of your crimes A Fifth One of the crimes to which you pled guilty in open court was soliciting a minor for prostitution true Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe how the solicitation to which you pled guilty was accomplished MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Can you tell me what the form objection was to that MR PAGLIUCA Please tell me how the solicitation was accomplished MR CASSELL Yes MR PAGLIUCA Okay Well youre asking for a legal definition from this lay witness as to solicitation how it was accomplished I dont know what that means Your question is vague its ambiguous it calls for a legal conclusion Its also lacking in foundation MR CASSELL Because MR PAGLIUCA Well as I understand it your position is that he pled guilty to Page Epstein Confidential made-up crimes that didnt have a factual basis and this was a conspiracy between Mr Epstein and the U.S Attorneys Office to avoid prosecution for federal criminal charges which is the basis for your challenge to in the CVRA litigation as I understand your pleadings So Im not exactly sure how you can actually have a good faith basis for asking that question given your position in writing MR CASSELL All right Youve mischaracterized our position And I imagine well have to discuss that later MR PAGLIUCA Sure MR CASSELL Since there were objections to form let me just try to ask a series of questions then to avoid the form objection BY MR CASSELL How did you accomplish the crime that you pled guilty to MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL What did you do that led you to plead guilty MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What was your understanding of the legal crime to which you were pleading guilty MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What was your understanding of what you were admitting in open court that day MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Now with regard to the two crimes that you pled guilty where did those two crimes take place A Fifth And I suppose there could be a form objection to that question being compound So to Page Epstein Confidential obviate any issue Im going to ask you was one of the victims in that case a girl who was years old who we could identify by initials S.G MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL And Mr Goldberger is if we refer to the victim in I believe it was Count or at least one of the accounts by S.G Is that an acceptable way to proceed rather than putting her name into the record or could I write her name out and provide that to you and your client What would you I want to avoid putting the names of 14-year-old sex victims into the transcript here MR GOLDBERGER Its your deposition MR CASSELL All right So what Im going BY MR CASSELL Sir you understand when I use the term S.G who Im referring to true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR CASSELL And what Im going to do is write the name of the victim and provide that to Mr Goldberger and to Mr Pagliuca now so that when I use the term S.G both Mr Goldberger and Mr Pagliuca will have that MR GOLDBERGER Thank you MR CASSELL And if you and then we should also provide that of course now to Mr Epstein so that hell MR GOLDBERGER Hes hes seen it MR CASSELL Okay And then Im going to do the same thing with the second witness Im going to refer to her by the initials And Im providing Let the record will reflect Im providing the the full name of to Mr Goldberger Mr Pagliuca and Mr Epstein has seen it as well BY MR CASSELL Please describe how you accomplished the solicitation of S.G MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please describe how you accomplished the solicitation of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Where was the solicitation of S.G accomplished MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Where was the solicitation of accomplished MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that the solicitation occurred in your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Isnt it true sir that the solicitation of S.G occurred in your Florida or I should say Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who was regularly in your Palm Beach mansion at the time of the solicitation of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Could I understand the form objection to that question MR PAGLIUCA Who was regularly in Again these are vague questions with no time frame which is the form problem of your questions BY MR CASSELL Sir with regard to my questions I want you to understand that the time frame is the same time frame for the crime to which you pled guilty Page Epstein Confidential With regard to that time frame who was regularly in your house MR PAGLIUCA Form and foundation objection THE WITNESS Fifth BY MR CASSELL Sir isnt it true that when you solicited for sex Maxwell was regularly in your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true that when you solicited S.G for sex Maxwell was regularly in your Palm Beach mansion MR PAGLIUCA Object to form and foundation And here Mr Cassell there is no evidence that Ms Maxwell was quote unquote regularly in the Palm Beach mansion during the time frame that youre talking about And so there is no good faith basis to ask that question Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR CASSELL I disagree with your understanding of the record but well take that up at a later time BY MR CASSELL How old was S.G when you solicited her for sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How old when you solicited her for sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that S.G was under the age of when you solicited her for sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Indeed sir isnt it true that S.G was under the age of when you solicited her for sex Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How old when you solicited her for sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir was under the age of when you solicited her for sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true you arranged for-24 to come to your Palm Beach mansion for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true that you arranged for S.G to come to your Palm Beach mansion for sexual Page Epstein Confidential purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true that you had sex with S.G at your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true that you had sex with at your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir it required logistical arrangements for A.H to come to your Palm Beach mansion true MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL Sir it required logistical arrangements Page Epstein Confidential for S.G to come to your Palm Beach mansion true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who helped make the logistical arrangements for S.G to come to your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who arranged who made Im sorry Let me strike that Let me start over Who made the logistical arrangements for S.G to come to your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true that Maxwell made the logistical arrangements or assisted with the logistical arrangements for S.G to come to your Palm Beach mansion MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation And again there is no good faith basis to ask this question There are no facts supporting any inference from that question Mr Cassell MR CASSELL I disagree with your reading of the record on that BY MR CASSELL You can answer A Fifth Isnt it true that Maxwell helped to make the arrangements to come to your Palm Beach mansion either directly or indirectly MR PAGLIUCA Object to form and foundation And again there is no evidence suggesting that that occurred with Ms Maxwell on being involved and there is no good faith basis to ask that question BY MR CASSELL Mr Epstein Mr Pagliuca just said there was no good faith basis for me to ask that last question Its true sir that you could give us a Page Epstein Confidential very significant good faith basis for me asking that question isnt it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact at that time Maxwell was regularly at your Palm Beach mansion true MR PAGLIUCA Object to form and foundation and asked and answered Same objections THE WITNESS Fifth BY MR CASSELL Who was running your Palm Beach mansion in MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Who was running your Palm Beach mansion in MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Who was running your Palm Beach mansion in Page Epstein Confidential MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Who was running your Palm Beach mansion in MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Sir isnt it true that Ms Maxwell was running your Palm Beach mansion in MR PAGLIUCA Object to form and foundation Again theres no evidence to suggest Ms Maxwell was running anything THE WITNESS Fifth BY MR CASSELL Mr Epstein there is lots of evidence to suggest that Ms Maxwell was running your home from through about true MR PAGLIUCA Object to form and foundation Argumentative THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Sir Miss Maxwell was running your Palm Beach mansion in true MR PAGLIUCA Object same objections that Ive raised before This is asked and answered MR CASSELL With regard to asked and answered MR PAGLIUCA I think so THE WITNESS Fifth BY MR CASSELL Sir Ms Maxwell was running your Palm Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir Ms Maxwell was running your Palm Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir Miss Maxwell was running your Palm Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir Ms Maxwell was running your Palm Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir Ms Maxwell was running your Palm Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who had access to the financial accounts for your Palm Beach mansion in A Fifth Sir isnt it true that Ms Maxwell had access to the financial accounts for your Palm Beach mansion in MR PAGLIUCA Object to form and Page Epstein Confidential foundation And again theres no evidence to suggest that Ms Maxwell had access to financial accounts of Mr Epstein in THE WITNESS Fifth BY MR CASSELL Ms Maxwell did indeed have access to some of your financial accounts in true sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Mr Cassell can we just take a 30-second break I think I have a logistical problem when I when I connected Mr Weinberg I used a line that was on service So I mean give me two seconds MR CASSELL All right And were just going to confer for a moment if thats all right MR GOLDBERGER Thank you VIDEO TECHNICIAN Off the record at a.m A recess was taken Page Epstein Confidential VIDEO TECHNICIAN On the record at a.m MR GOLDBERGER Thank you for the break BY MR CASSELL Sir who did you talk to during the break A Fifth MR GOLDBERGER And attorney-client MR CASSELL But you believe theres a good faith basis for him to say what was just discussed would be incriminating MR GOLDBERGER Objections been raised Privileged has been invoked MR CASSELL All right BY MR CASSELL Without going into the substance of any communications who did you speak to during the break A Fifth MR GOLDBERGER Attorney-client Again were raising attorney-client privilege without waiving any Fifth Amendment privileges MR CASSELL Understood Page Epstein Confidential BY MR CASSELL You know who Alfredo Rodriguez is sir true A Fifth Who is Alfredo Rodriguez A Fifth Alfredo Rodriguez was involved in some household management issues in your Palm Beach mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did Alfredo Rodriguez do for you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who did Alfredo Rodriguez report to in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Sir isnt it true that Alfredo Rodriguez reported to Maxwell in MR PAGLIUCA Object to form and foundation Theres no evidence to suggest that he reported to Ms Maxwell THE WITNESS Fifth BY MR CASSELL Who is Sarah Kellen A Fifth You know Sarah Kellen dont you A Fifth What did Sarah Kellen do for you at your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did Alfredo Rodriguez work for you in A Fifth How many years did Alfredo Rodriguez work for you A Fifth Page Epstein Confidential Sarah Kellen reported to Maxwell true MR PAGLIUCA Object to form and foundation Theres no evidence to suggest that Miss Kellen reported to Miss Maxwell THE WITNESS Fifth BY MR CASSELL Mr Epstein you could give us lots of evidence that Sarah Kellen reported to Maxwell true MR PAGLIUCA Object to form Foundation Argumentative THE WITNESS Fifth BY MR CASSELL Sarah Kellen and Ghislaine Maxwell both assisted you in the solicitation of S.G true MR PAGLIUCA Object to form and foundation And again theres no evidence to show that Miss Maxwell participated in the solicitation of anybody THE WITNESS Fifth BY MR CASSELL Please give us all the evidence that Maxwell participated in the solicitation of minors Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sarah Kellen and Ghislaine Maxwell both assisted in the solicitation of true MR PAGLIUCA to form and foundation Again there is no evidence to suggest that thats true And Mr Cassell if you have some good faith basis and you want to put it on the record thats fine I have the Palm Beach Police Department reports here We deposed Detective Racari You know as well as I do that theres no evidence to suggest that Ms Maxwell was involved at all MR CASSELL I move to strike the speaking objections Theyre improper in this deposition And theres a time and a place to put on both your point of views on these issues and of course our point of view as well MR PAGLIUCA Well thats fine You Page Epstein Confidential know if we can understand that my form and foundation objection encompasses what youre deeming as speaking objections I can certainly truncate this and just make my form and foundation objections MR CASSELL My understanding of the proper procedure is you should object on form and foundation unless I ask for further clarification Thats all you need to make the record MR PAGLIUCA Okay And that form and foundation objection then would include my position that theres no good faith basis to be asking these questions is that correct MR CASSELL Thats correct That would be your position And of course our position would be to the contrary MR PAGLIUCA I understand Im just trying to make sure that were not waiving anything and Im happy just to MR CASSELL Sure MR PAGLIUCA simply to object to form and foundation preserving any objections I have to the questioning and the Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential process of the proceeding Fair MR CASSELL You would be preserving obviously a form objection and a foundation objection MR PAGLIUCA Sure I guess the questions then becomes what does that mean MR CASSELL Right MR PAGLIUCA So I can keep objecting as I am or we can have some agreement But why dont we keep going and well see what happens MR CASSELL Right And I it would be my position that anything beyond form and foundation should be stricken MR PAGLIUCA Okay MR CASSELL Unless you can and thats thats the way to proceed Plaintiffs Exhibit JE1 Transcript of the deposition of Ms Maxwell taken on April 22nd was marked for identification BY MR CASSELL All right Sir I want to hand you a document which Im document Im going to mark as JE1 for Jeffrey Epstein And Ill represent and Page Epstein Confidential provided a copy to both Mr Goldberger and Mr Pagliuca I represent that this is a transcript of the deposition of Ms Maxwell taken on April 22nd You have that document in front of you sir A Yes If I could ask you to flip to page And since there are two sets of numbers this would be the smaller set of numbers up on the for example the top of the page These these are four pages per page And page Id like to direct your attention to page line Actually Im sorry page line Do you see where I am sir A Yes On line there is a question Did Jeffrey was it Jeffreys preference to start a massage with sex Do you see that question sir A Yes And then if we skip over two lines where theres a form and foundation objection we go to line where there is an answer given by Page Epstein Confidential Ms Maxwell Do you see that answer A Yes The answer is I think you should ask that question of Jeffrey Do you see that answer A Yes So following up on Ms Maxwells suggestion Im going to ask you the same question Was it your preference to start a massage with sex A Fifth It is true that your preference was to start a massage with sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL I dont know that I completely finished the question So let me just re-ask it It is true that your preference was to start a massage with sex correct MR PAGLIUCA Objection to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL To your knowledge when she was deposed on April 22nd Maxwell knew that your preference was to start a massage with sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It is true that you directed Maxwell to recruit girls under the age of who would have sex with you all under the guise of providing a massage correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL One of the girls under the age of with whom you had massages starting with sex was Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Maxwell has been present many times when you have had massages starting with sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL All right Now I want to go in the same exhibit a little further in at page All right On page line do you see line on page A Yes And do you see a question there that reads So would Virginia be brought on trips that were for the purpose of work and decorating the house Do you see that question A Yes And then do you see following on immediately the answer from Ms Maxwell Like I said I never worked with her but you would have to ask Jeffrey what he brought her on the trip for Do you see that answer A Yes And so I represent to you that thats an Page Epstein Confidential answer from Ms Maxwell and will you understand that as I ask further questions with regard to this transcript A Yes So following up on Ms Maxwells direction I would like to ask you why did you bring bring Virginia on the trip to New Mexico MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You did bring Virginia on a trip to New Mexico true sir MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL Why did you bring Virginia on your trips with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL With regard to the New Mexico trip that were discussing here isnt it true that you brought Page Epstein Confidential Virginia there for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was fully aware that Virginia was in New Mexico for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Can you think of any other purpose which an attractive 17-year-old girl would be on your property at that time sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell knew there was no other purpose for Virginia being there at that time other than sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Is there anyone else I can talk to besides you Virginia and Maxwell to give information about why Virginia was at your ranch in New Mexico MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL There is no one else I can talk to you besides you Virginia and Maxwell to get exact information about why Virginia was at your ranch in New Mexico true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Lets go now to page actually let me ask one quick question while Im thinking about it or Ill come back to that in a moment Lets go to page You see on line of you see a question What has Jeffrey told you about Virginia Roberts Do you see that sir A Yes Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential And then theres an answer in line Do you see that A Yes The answer is that She is a liar Do you see is I represent to you that that is Ms Maxwell stating that you said Virginia Roberts is a liar Is that accurate testimony from Ms Maxwell A Fifth On line thats not accurate testimony from Ms Maxwell is it MR PAGLIUCA Object to form and foundation THE WITNESS Sorry Repeat the question BY MR CASSELL It is not accurate testimony what we see on line there is it A You said line I believe sir Im sorry Let me A Sorry Yeah Lets So you see a question on line correct Page Epstein Confidential sir A Yes And the question on line is What has Jeffrey Epstein told you about Virginia Roberts Thats the question there A Yes And on line theres an answer from Ms Maxwell that She is a liar Do you see that answer A Yes That answer is not accurate testimony is it sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Ms Maxwell gave that testimony she well knew that Virginia was not a liar true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Going now to line there is a question What does he base that on Page Epstein Confidential Do you see that question A Yes And then skipping over a form and foundation objection on line we see an answer from Maxwell You would have to check with him Do you see that A Thats incomplete but yes And then the sentence carries on I can tell you why I think she is a liar Im happy to do that Do you see the rest of that A Yes But I want to focus in on the first part of that sentence You would have to check with him Do you see that answer A Yes And that answer you understand in context to be a request from Maxwell that we check with you Do you understand that MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL So I would like to check with you now Page Epstein Confidential What do you base your assessment of Ms Roberts credibility on A Fifth Its true sir that Virginia is highly credible isnt it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Virginia has said you were a sex trafficker thats a true statement right sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Virginia has said that you had sexually abused her thats a true statement isnt it sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And when Virginia said Maxwell sexually abused her you know that to be a true statement as Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential well dont you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Virginia has told the truth about you using Maxwell to recruit girls for you to sexually abuse true sir MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL Please give us all the information that you have regarding how credible Virginia is MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please give us all information you have about Virginias credibility on issues relating to sex abuse MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please give us all information you have showing that Virginia is credible about allegations shes made against you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please give us all the information you have about how Virginia is credible with regard to her allegations against Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Is there anybody else that I could check with besides you to follow up on Ms Maxwells suggestion of obtaining information about Virginias credibility with regard to sexual abuse by you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir its true that the only one who knows Page Epstein Confidential about threesomes between you Maxwell and her would be the three of you correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And when I refer refer to a threesome in todays deposition will you understand that Im referring to sexual activity among three people occurring essentially simultaneously MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your understanding of the term threesome A Fifth Without regard to any conduct that you may or not have undertaken in the past what do you understand the word threesome to mean A Fifth Lets now go to page of the transcript Oh Im sorry Actually lets go to the very bottom of page Page Epstein Confidential Do you see line on page A Yes And the question is Thats all he said about Virginia Do you see that question A I dont see a question mark do you On line of page A Yes And so this is a reference back to line on page Do you see line on page A Yes And the answer there from Maxwell is All he that is Epstein in context told me that she is a liar Do you see that answer Do you see the answer there on line A Yes That is not accurate testimony is it sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you told Ms Maxwell that you were very concerned that people would learn the truth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential about your activities with Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact both you and Ms Maxwell were very concerned that people would learn the truth about Virginias allegations true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And you and Ms Maxwell undertook a plan at that point to try and undercut Virginias credibility true MR PAGLIUCA Object to form and foundation Can you mark those for me Reporter those last three questions Thank you THE WITNESS Fifth BY MR CASSELL Im sorry On page line theres an answer We went through all the lies that you have sold to the papers and sold in general and we have Page Epstein Confidential analyzed her lies and your lies and your inappropriate behavior in detail Do you see that answer A Yes That is not a fair and accurate recounting of your conversation with Maxwell is it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact the two of you were not worried about the lies that Virginia was telling but the truthful statements let me strike that In fact you were not concerned in any way about any lies Virginia was telling because she was not lying true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You were concerned that Virginia was telling the truth werent you MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL You never denied to Maxwell that you had sexual relations with Virginia did you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And in fact Maxwell well knew that you had sexual relations with Virginia because she had been with you when you were having sexual relations with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Lets go now to page of the transcript If you look at line on page do you see a question Is it an obvious who did lead her up to Jeffreys room while you were talking to her mother Do you see that question A Yes And Ill represent to you that the her in Page Epstein Confidential that question is a reference to Virginia Do you understand that to be the question A Yes And if we go over onto the next page then we see Answer You would have to ask Virginia I dont know if she was led up to his room Do you see that answer A Yes Theres actually another person that we could ask apart from Virginia who would know who led her up to your room isnt that true sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The first time you met Virginia where did you meet her A Fifth Isnt it true that the first time you met virgin what was in your massage room in your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Isnt it true that Maxwell led Virginia up to your Palm Beach mansion massage room the first time you met her MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You saw Maxwell bringing Virginia up to your room true sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that it was standard operating procedure for Maxwell to bring underage girls up to your room MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that it was standard operating procedure for Maxwell to bring underage girls up to your room for you to sexually abuse Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that Maxwells sworn testimony is inaccurate when she says she didnt bring Virginia up to your room MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that Maxwell was perjuring herself when she said she didnt know who brought Virginia up to your room MR PAGLIUCA Object to form foundation THE WITNESS Fifth BY MR CASSELL Lets go now to page of the transcript line Do you see the question there 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 Page Epstein Confidential Jeffrey Epsteins room Do you see that question A Yes And then you see an answer there I have never participated at any time with Virginia in a massage with Jeffrey Do you see that answer A Yes And I represent to you the answer is being given by Ms Maxwell during a sworn deposition Will you understand that with regard to my questions here A Yes Miss Maxwells testimony is not truthful is it sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you Maxwell and Virginia all had sexual contact together at the same time on multiple occasions true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL How many times have you Maxwell and Virginia had sexual contact together MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On multiple occasions you and Maxwell jointly participated in sexual abuse of Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you and Maxwell ever jointly participated in the sexual abuse of Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times have you and Maxwell jointly participated in the sexual abuse of Virginia MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Your understanding of all the facts in this case is that Maxwell was lying when she denied sexual abuse of Virginia true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL If Maxwell had told the truth in her deposition she would have admitted to sexually abusing Virginia true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL When you and Maxwell were jointly sexually abusing Virginia who were the witnesses to that activity MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that when you and Maxwell Page Epstein Confidential were jointly sexually abusing Virginia you two were the only two witnesses who could see what was going on MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Are there any other witnesses I should call to try to depose and talk to to see whether you and Maxwell were jointly sexually abusing Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times did you and Maxwell have sex with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times did you have sex with Virginia MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL How many times to your knowledge did Maxwell have sex with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir its true that you had sex with Virginia dozens if not hundreds of times isnt that true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And to your knowledge Maxwell had sex with Virginia dozens and dozens of times true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL What years did you and Maxwell have sex with Virginia Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true that you and Maxwell had sex with Virginia in the year true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true that you and Maxwell had sex with Virginia in the year true MR PAGLIUCA Object to forma and foundation THE WITNESS Fifth BY MR CASSELL You had sex with Virginia repeatedly when she was under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You also had sex with Virginia when she was under the age of true Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You had sex with Virginia when she was years old true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell had sex with Virginia when she was true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell had sex with Virginia when she was true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL If I could just confer with counsel for a moment A discussion was held off the record Page Epstein Confidential BY MR CASSELL You have a sexual preference for having sex with girls between the ages of to true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Between and you sexually abused more than girls under the age of in Florida true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Between and you also sexually abused dozens of girls in other locations as well true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL In about you and Maxwell asked Virginia to carry a baby for the two of you true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL When you asked Virginia to carry a baby for you part of your proposal was for her to turn the baby over to the two of youth to the two of you at the end of the pregnancy true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In about June or July of you and Maxwell took Virginia to a hospital in New York City because of a problem she was having with vaginal bleeding true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you and Maxwell took Virginia to the hospital the two of you lied to the hospital to make her age rather than true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL You and Maxwell have had so-called threesomes i.e sexual activity with three people at the same time with multiple girls who were under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Many of these threesomes occurred in Florida true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell have also participated in sex orgies with Virginia true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell participated in sex orgies with Virginia while she was under the age of Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell participated in sex orgies with many other girls true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth THE COURT REPORTER Excuse me Can we go off the record Im sorry VIDEO TECHNICIAN Off the record at a.m A discussion was held off the record VIDEO TECHNICIAN On the record at BY MR CASSELL Sir without regard to any conduct that you may or may not have committed what do you understand the word orgy to mean A Fifth Sir in the summer of you first met Miss Virginia Giuffre in your Palm Beach mansion Page Epstein Confidential true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell was the person who first introduced you to Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL At the time Virginia was just years old true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you first met Miss Giuffre and I guess Ill refer to as Virginia for the rest of these questions her physical appearance to you was that she was only years old true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL The reason Maxwell introduced Virginia to you was so that you could have sex with Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact on a number of occasions in and both you and Maxwell simultaneously had sex with Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without going into detail please describe the nature of the sex acts that you performed on Virginia in and MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without going into detail please describe the nature of the sex acts that you observed Maxwell Page Epstein Confidential perform on Virginia in and MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In the fall of you and Maxwell trained Virginia on how to cater to the sexual desires of your male friends true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And from through you forced Virginia to interact sexually with many of your male friends true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you forced Virginia to sexually interact with Harvard Law Professor Alan Dershowitz MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL It would be a fair statement to describe Virginias situation from the fall of through July as your sex slave true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You understand the term sex slave dont you sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without to regard to any conduct that you may or may not have committed what does the term sex slave mean to you A Fifth Plaintiffs Exhibit JE2 Document with titles of books was marked for identification BY MR CASSELL Im going to show you what Ill mark as JE2 Page Epstein Confidential A Are you finished with this Yeah Were through with that now You recognize the books listed on this document dont you sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The first book listed here as being sold by Amazon is Slave Craft Road Maps For Erotic Servitude Principles Skills and Tools Do you see that sir A Yes That was a book you ordered sir true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The second book listed here is Training With Ms Abernathy A Workbook For Erotic Slaves and Their Owners Do you see that there sir A Yes That was another book that you ordered Page Epstein Confidential true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You relied on the Defendant in this case Ghislaine Maxwell to keep Virginia available for to you sexually abuse true MR PAGLIUCA Object to form and foundation THE WITNESS Are we finished with this BY MR CASSELL Yes MR CASSELL Did we get an answer to to that MR PAGLIUCA Yes you did We did not MR GOLDBERGER Yes I thought he said the Fifth BY MR CASSELL Let me just re-ask the question because its an important one Sir you relayed on the Defendant in this Page Epstein Confidential case Ms Maxwell to keep Virginia available available for you to sexually abuse true MR PAGLIUCA Objection to the form and foundation THE WITNESS Fifth BY MR CASSELL What did Miss Maxwell do for you in the years and MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please briefly describe the nature of the interactions you observed between the Defendant in this case Ms Maxwell and the Plaintiff in this case Ms Virginia Roberts from Miss Virginia Roberts Giuffre from the fall of through the summer of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason youre taking the Fifth with regard to Maxwells interactions is that she was Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential involved in the sexual abuse of Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the massage room upstairs in your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that you do have a massage room upstairs in your Palm Beach mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What kinds of rooms do you have upstairs in your Palm Beach mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In that massage room Maxwell kept a basket Page Epstein Confidential of sex toys true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And if we narrow the time frame down to the years and Maxwell had a basket of sex toys there true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell used sex toys on Virginia in your presence true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your understanding of the term sex toy without regard to any conduct that you may or may not have committed in the past A Fifth Before August Maxwell forcibly penetrated Virginia with an artificial penis or dildo Page Epstein Confidential in your presence true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell flew together with Virginia over times when Virginia was under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times did you and Maxwell fly together with Virginia before August of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell trafficked Virginia while she was under the age of to other men for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL During the period of time to you were having sex as many as three times a day true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And during that time period Maxwell was bringing girls to you to take the pressure off her to have that much sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell asked girls under the age of to bring other girls under the age of to you for sexual purposes true MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth Can I have some water MR CASSELL Uh-huh BY MR CASSELL Maxwell was in charge of coordinating the Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential girls who came to your house for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell and your house staff used message pads to coordinate the schedule for the girls coming over to your houses true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell often paid the girls who came over to your house for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who paid the girls who came over to your house for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Maxwell used the prospect that girls could become models for Victorias Secret to lure them over to your house true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How did you lure girls over to your house for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What techniques did you see Maxwell using to lure girls over to your house for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On or about March 9th you the Defendant in this case Ms Maxwell Emmie Taylor and Virginia flew on your private jet from Tangiers to Luton International Airport in the London England Page Epstein Confidential metropolitan area MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On that trip you stayed in London at Maxwells flat true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL At that time it would be a fair assessment to say that Maxwell was your girlfriend true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In March of who was your girlfriend A Fifth During that trip in March of Maxwell Virginia and Prince Andrew that is the Duke of York all met at night inside Maxwells flat true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Did you meet Prince Andrew the Duke of York in about March of in London A Fifth MR CASSELL I guess well mark this as JE3 Plaintiffs Exhibit JE3 Photograph depicting Prince Andrew Maxwell and Virginia was marked for identification MR CASSELL Ive got copies for opposing counsel here MR GOLDBERGER Thank you BY MR CASSELL Showing you whats been marked as JE3 Do you have that in front of you sir A Yes Do you recognize that photograph MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir this is a photograph depicting Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Prince Andrew Maxwell and Virginia all together true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You took this photograph right sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who took this photograph A Fifth If you look at the person on the left the male figure in the photograph do you see that person there A Yes That person has his arm around the bare midriff of a young girl true MR PAGLIUCA Object to form and foundation THE WITNESS Yes BY MR PAGLIUCA Thats Prince Andrews arm around the waist Page Epstein Confidential of Virginia touching her bare midriff true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The only persons inside of Maxwells flat at this time in addition to you and Maxwell were Virginia and Prince Andrew true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Where was this photograph taken MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL This photograph was taken in Maxwells flat in London true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You immediately recognized where this picture was taken didnt you sir Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And based on your understanding of the circumstances surround the taking surrounding the taking of this photograph Ms Maxwell would have immediately identified who was in this photograph and where it was taken true MR PAGLIUCA Object to form and foundation THE WITNESS Could you repeat that question Im sorry Could you repeat that question BY MR CASSELL And based on your understanding of the circumstances surrounding the taking of this photograph Ms Maxwell would have immediately identified who was in this photograph true MR PAGLIUCA Same objection THE WITNESS Fifth BY MR CASSELL And based on your understanding of the circumstances surrounding the taking of this Page Epstein Confidential photograph Ms Maxwell would have immediately identified where this photograph was taken true MR PAGLIUCA Same objection THE WITNESS Fifth BY MR CASSELL The only persons I think we may have already asked this Lets see Let me just ask this to make sure The only persons inside of Maxwells flat at that time in addition to you and Maxwell were Virginia and Prince Andrew true MR PAGLIUCA Form form and foundation Asked and answered THE WITNESS Fifth BY MR CASSELL Prince Andrews security detail remained outside of Maxwells flat when this photograph was taken true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Shortly after this photograph was taken you and Maxwell both observed Prince Andrew and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Virginia go into the room depicted in the back of the photograph true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And in this photograph you do see a room depicted in the back A Fifth Youre taking the Fifth about what is shown in this photograph A I I cant see anything Im sorry MR GOLDBERGER Okay So its so were not were not raising Fifth Amendment privilege You cannot your answer is you cannot see what Mr Cassell is referring to THE WITNESS Correct MR GOLDBERGER Okay BY MR CASSELL Do you see a window depicted in this photograph A I dont know what it is Im sorry Do you see a white light reflecting off of Page Epstein Confidential a blue surface in this photograph A Yes Does that appear to you to be a window A Not necessarily no MR GOLDBERGER Why dont you just assume arguendo that that that what what youre trying to have Mr Epstein identify is a room and then we can go on from there MR CASSELL All right BY MR CASSELL That room is a bedroom in Ms Maxwells flat true MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell instructed Virginia to have sex with Prince Andrew true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact it would be a fair assessment of Page Epstein Confidential all the circumstances surrounding this situation to say that you forced Virginia to have sex with Prince Andrew MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What would have happened to Virginia if she had refused to have sex with Prince Andrew MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL At the time Virginia retired to the bedroom with Prince Andrew Maxwell was in possession and control of Virginias U.S pass passport true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who had Virginias passport when she entered England MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL After she was inside of English territory who main con remained in control of her passport MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Virginia was years old at this time true A Fifth MR PAGLIUCA Object to form and foundation THE WITNESS Sorry Fifth BY MR CASSELL It was your understanding that Prince Andrew and Virginia was retiring to this bedroom to have sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you understand Virginia and Prince Andrew to be doing that evening Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL Shortly after Prince Andrew and Virginia had sex Virginia gave you a full report about the details of the sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did Virginia tell you anything after this photograph was taken about Prince Andrew MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL Did Prince Andrew tell you anything about what he had done with Virginia in the room MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that Prince Andrew thanked you for making Virginia available to him for sexual purposes Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You had previously instructed Virginia that she had to give you a full report on the details of what men like Prince Andrew did to her so that you would have blackmail material you could use true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What instructions if any had you given to Virginia about what she should say after she had sex with men MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL What did you do with the information that Virginia gave you after she had sex with men MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL What if anything did you do with the information that Virginia gave you after you had sex after she had sex with men MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Approximately the next day after this photograph was taken you made Virginia report to you in detail about Prince Andrews sexual preferences true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What if anything do you know about Prince Andrews sexual preferences MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL We can go into the details if this would help refresh your memory but isnt it true that Virginia recounted specific behavior that Page Epstein Confidential Prince Andrew requested before sexual intercourse MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason you asked for a detailed review of Prince Andrews sexual activities was so that you would have blackmail information about him true MR PAGLIUCA Object to form Asked and answered THE WITNESS Fifth BY MR CASSELL Why did you ask for a detailed review of Prince Andrews sexual activities MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You had previously told Virginia it was part of her job to give you detailed information about the men that you and Maxwell forced her to have sex with true MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL When Virginia had sex with men that you forced upon her what was her job MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What would have happened to Virginia if she had refused your request to have sex with men MR PAGLIUCA Objection to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that you would have threatened Virginia and in fact potentially harmed her if she refused to have sex with the men you provided to her MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What kind of threats did you make against Virginia when she was with you Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the threats you have ever made against Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you every made threats against Virginia A Fifth At one point you told Virginia that you needed detailed sexual information from the men she had sex with so those men would owe you favors true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you provided Virginia to men to have sex they then did owe you favors true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL In Virginia was approached by Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was one of the main women whom you used to procure underage girls for sexual activities true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It was your understanding that Maxwell met Virginia at the Mar-a-Lago Club in Palm Beach in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In you were a member of the Mar-a-Lago Club true Page Epstein Confidential MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL In Ms Maxwell had access to the Mar-a-Lago Club true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason Maxwell had access to the Mar-a-Lago Club in was because of your connections to the club true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was a primary co-conspirator in your sexual abuse scheme true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was a primary co-conspirator in your sex trafficking scheme true Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell herself regularly participated in your sexual exploitation of minors true MR PAGLIUCA Object to form and found THE WITNESS Fifth BY MR CASSELL In Maxwell herself regularly participated in your sexual exploitation of minors true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell herself regularly participated in your sexual exploitation of Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did Maxwell participate in your sexual Page Epstein Confidential exploitation of Virginia MR PAGLIUCA Object to foundation THE WITNESS Fifth Can we take a break so I can stand up MR CASSELL Sure VIDEO TECHNICIAN Off the record at A recess was taken VIDEO TECHNICIAN This is the beginning of disc two On the record at BY MR CASSELL Has Maxwell ever made any threats against Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that Maxwell has threatened Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Has Maxwell ever made any threats against other girls that you interacted with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that Maxwell has made threats against other girls with whom youve interacted MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Maxwell ever told girls that they should keep quiet about the sexual activities you have had with them MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir Maxwell has made threats against girls to tell them or force sorry Let me to start over Page Epstein Confidential Its true sir that Maxwell has told girls they should keep quiet about the sexual activities you had with them right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Maxwell ever told girls they should keep quiet about the sexual activities she had with them MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that Maxwell had told girls they should keep quiet about the sexual activity she had with them right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What if anything did Maxwell tell Virginia would happen to her if she refused your demands to have sex Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that Maxwell threatened Virginia if she refused to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell regularly participated in your sexual exploitation of Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell persuaded Virginia to come to your mansion in true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Virginia was years old when Maxwell persuaded her to come to your mansion true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The fashion in which Maxwell persuaded Virginia to come to your mansion was similar to the manner in which you coerced dozens of other children to come to your mansion true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Virginia be sorry When Virginia began giving you a massage you and Maxwell turned it into a sexual encounter true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You had done the same thing with many other victims true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL After you first sexually abused Virginia you became enamored with her true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How did you feel about Virginia after you first met her MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL With the assistance of Maxwell you converted Virginia into what is commonly referred to as a sex slave true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you interacted with Virginia in and what were you doing with her MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL You sexually exploited Virginia from the summer of through about September true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In Virginia managed to escape to a foreign country and hide from you true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In when Virginia escaped she was also hiding from Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why would Virginia have wanted to hide from you in MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Virginia was hiding from you because she was afraid of you true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Virginia was hiding from Maxwell because she was afraid of Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you and Maxwell sexually abused Virginia in Palm Beach Florida true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you and Maxwell sexually abused Virginia in New York City true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you and Maxwell Maxwell sexually abused Virginia in New Mexico true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you and Maxwell sexually abused Virginia in the U.S Virgin Islands MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through you and Maxwell sexually abused Virginia on your private jet MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You abused Virginia other places than the ones Ive just mentioned true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell sexually abused Virginia in places other than the ones I just mentioned true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please list all the places that you had sex with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please list all the places where to your knowledge Maxwell had sex with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell sexually trafficked Virginia by forcing her to have sex with politically Page Epstein Confidential connected and financially powerful people true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Your purpose in sending Virginia to such powerful people was to ingratiate yourself with them true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwells purpose in sending Virginia to such powerful people was to ingratiate herself with them true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason you and Maxwell were sending Virginia to these powerful people was for business personal political and financial gain true MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Another reason was to gain potential blackmail information true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was fully involved in sending Virginia to various powerful people for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And Maxwell was hoping to obtain blackmail information as well true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You observed Maxwell sexually abuse Virginia in true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL You observed Maxwell sexually abuse Virginia in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times have you observed Maxwell sexually abuse Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How many times have you observed Maxwell have any form of sexual interaction with Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL One powerful individual that you and Maxwell forced Virginia to have sexual relations with Page Epstein Confidential was former former Harvard Law Professor Alan Dershowitz true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell required Virginia to have sexual relations with Dershowitz on numerous occasions while she was a minor true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell forced Virginia to have sexual relations with Dershowitz in Florida New York New Mexico and the U.S Virgin Islands among other places true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please list all the places where you forced Virginia to have sexual relations with Dershowitz MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL In addition to being a participant in the abuse of Virginia and other minors Dershowitz was an eyewitness to the sexual abuse of many other minor girls by you and Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Dershowitz was an eyewitness to the sexual abuse of many other minors by you true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL One way to describe Maxwells role for you was as a madam true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve heard the term madam used in Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential reference to someone who is a procurer of women or other girls for sex right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What was Maxwells role for you in and MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What was Maxwells role with you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Using the term madam as I had previously defined it wouldnt it be fair to say Maxwell was a madam for you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Wouldnt it fair to say that she was an madam for you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Wouldnt it be fair to say that she was a madam for you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It would be fair to say that Maxwell assumed assumed a position of trust for the girls whom you sexually abused including Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You know that Maxwell had sex with dozens of underage girls true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Maxwell had sex with Virginia in the U.S Virgin Islands New Mexico New York France and many other locations true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL From through what kinds of pictures did you have in your Florida mansion A Fifth From through what kind of pictures did you have in your New York City mansion A Fifth From to what kinds of pictures did you have in the U.S Virgin Islands residence A Fifth Maxwell took sexually explicit pictures of many underage girls true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL What kinds of pictures have you seen Maxwell take MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL Have you ever seen Maxwell take pictures of girls under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that youve seen Maxwell take many picture of girls under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you displayed pictures of naked girls throughout your home in Florida true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL In fact you displayed pictures of naked girls throughout your home in New York true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you displayed pictures of naked girls throughout your home in the U.S Virgin Islands true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you displayed pictures of naked girls throughout your home in New Mexico true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Tell me about all the circumstances in which youve seen Maxwell providing cameras to people MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL You had Maxwell provide cameras to underage girls true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Your purpose in having Maxwell provide cameras to underage girls was to have them take sexually explicit pictures of themselves true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever seen Maxwell take a sexually explicit picture of an underage girl MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell viewed together sexually explicit pictures of girls under the age of true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the pictures of girls that youve seen Maxwell take MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Now you have interacted with Maxwell in England many times true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL I want you to understand that the next series of questions well be dealing just with your actions in England not with any of your actions in the United States Will you understand that with regard to my next questions A Yes While you were in England you directed Page Epstein Confidential Maxwell to bring English females under the age of to you for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL While in England in Miss Maxwells private residence you observed Maxwell in the presence of English females under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL While in England Ms Maxwell brought you English females to satisfy your sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How young were the English girls that Maxwell brought to you MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe how many times you have seen Maxwell in private locations with girls under the age of in England MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You recognize the name Alexandra Dickson dont you sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Alexandra Dickson was an English girl recruited by Maxwell for your sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Tell me how you came to meet Alexandra Dickson in England A Fifth Page Epstein Confidential When you met Alexandra Dickson she was under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How old was Alexandra Dickson when you first met her MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Based on your understanding of English criminal law you have observed Maxwell commit English criminal offenses of a sexual nature in England true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever observed Maxwell commit a crime in England MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe for me all the crimes you have seen Maxwell commit in England MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL While in England you instructed Maxwell to go to public places to solicit English girls to have sex with you in England in exchange for compensation true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What instructions did you give to Maxwell in England about what she should do for you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe Maxwells interactions in England with females under the age of Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe Maxwells interactions in England with e-mails under the age of with whom you had sex MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have yourself solicited in public places English girls under the age of to have sex with you in exchange for compensation true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And just so Im clear you have in England yourself solicited in public places English girls under the age of to have sex with you in exchange for compensation true MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe your interaction with females under the age of in England MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe your interactions with females under the age of with whom you have had sex in England MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have had sex with females under the age of in England in exchange for compensation true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Based on your understanding of English criminal law you have committed domestic English sex offenses in England true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without going into any acts you have com may have committed what is your understanding of English criminal law regarding soliciting sex MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL During the time period to Maxwell and you lived together for significant parts of those years true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL During the time period to Maxwell was responsible for much of the day-to-day operation of your Florida mansion true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Who is the person you interacted with most in the year A Fifth Who was the person you interacted most in the year let me rephrase Who is the person that you interacted with the most in A Fifth Who is the person that you interacted the most with in A Fifth Isnt it true sir that the person you interacted with most in the year was Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true the person you interacted with most in the year was Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Who did you interact the most with in the year A Fifth Isnt it true sir that you interacted the most with Maxwell in the year MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who was responsible for the day-to-day operation of your Florida mansion in to MR PAGLIUCA Object to form and foundation Asked and answered THE WITNESS Fifth BY MR CASSELL Isnt it true Maxwell was responsible for much of the day-to-day operation of your Florida mansion in to MR PAGLIUCA Object to form and foundation Asked and answered THE WITNESS Fifth BY MR CASSELL During the time period to you Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential were sexually sexually intimate with Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have remained on friendly terms with Maxwell even through today true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How would you describe your relationship today with Maxwell A Fifth In the period to you directed Maxwell to recruit girls under the age of for you to use for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How did you get the girls that you sexually abused in to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The directions you gave Maxwell for recruiting girls for you was something to the effect of the younger the better true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever used the phrase The younger the better in the presence of Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that youve used the phrase The younger the better in the presence of Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL You instructed Maxwell then when she was recruiting girls for you she could bring you girls of any race except for African Americans true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever discussed the age of underage Im sorry Have you ever discussed the race of underage girls with Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why is it that you instructed Maxwell not to bring you African American girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Im now going to ask you a question series of questions about overseas locations and I Page Epstein Confidential want you to understand that each of these questions is asking solely about your activities in these overseas locations and its not in any way asking for any information about actions that you may or may not have committed in the United States Will you understand that with regard to these next questions A Yes You have an apartment in Paris France true A Fifth Maxwell has frequently been to your apartment in Paris France true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please list all the places in the world where you have an apartment A Fifth While Maxwell has been at your apartment in Paris France you have had numerous girls under the age of in your presence true MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL While she was with you in Paris Maxwell recruited French girls under the age of for to you sex with true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of your interactions with underage girls Im sorry Please describe all of your interactions with girls under the age of in France A Fifth My next series of questions again are only asking for your activities in the foreign country in question and that will be Thailand Will you understand that with regard to my next questions A Yes You have been to Thailand true A Fifth Have you ever been to Thailand Page Epstein Confidential A Fifth When you went to Thailand Maxwell accompanied you true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you went to Thailand who went with you A Fifth You saw Maxwell in the presence of Thai females under the age of in Thailand true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Describe what you did with Maxwell in Thailand MR PAGLIUCA Object to foundation THE WITNESS Fifth BY MR CASSELL While in Thailand you directed Maxwell to recruit Thai females under the age of for your sexual purposes solely in Thailand true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL While in Thailand Maxwell brought you females under the age of true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without going into any acts that you may or may not have committed what is your understanding of Thai criminal law regarding sex with girls under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever had sex with a Thai female under the age of in Thailand MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Have you ever had sex with anyone in Thailand MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the sexual activities you had in Thailand A Fifth My next series of questions are with regard to the country of Brunei and I want you to understand that these questions deal solely with your activities in Brunei All right A Yes In you flew to Brunei with Maxwell on your private jet true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever been to Brunei A Fifth Have you ever been to Brunei with Maxwell Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have had sex with girls from Brunei under the age of in Brunei MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the sex that youve that in Brunei MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell helped you find girls from Brunei for you to have sex with in Brunei true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did Maxwell do in Brunei with you MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Are you aware of inter interaction by Maxwell with women in Brunei MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Are you aware of any interaction by Maxwell with girls under the age of in Brunei MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the interactions you saw between Maxwell and girls from Brunei in Brunei A Fifth My next questions deal solely with your activities in the Czech Republic Have you ever been to the Czech Republic A Fifth Have you ever been to the Czech Republic with Maxwell Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please tell me about your sexual abuse in the Czech Republic of Czechs Czech girls under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever had sex in the Czech Republic MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please tell me who youve had sex with in the Czech Republic MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please tell me about Maxwells involvement Page Epstein Confidential in your sexual abuse of Czech girls in the Czech Republic MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell has been to the Czech Republic with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you went to the Czech Republic who did you meet MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Was Maxwell ever with you when you were in the presence of girls under the age of in the Czech Republic MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Its true sir that Maxwell was with you when you were in the presence of girls under the age of in the Czech Republic right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please name all of the countries not including the United States where you have seen Maxwell in the presence of females who lived in those countries under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe for me Maxwells sexual interactions with females under the age of in foreign countries with citizens of those countries MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Maxwell ever interacted with females Page Epstein Confidential under the age of in foreign countries MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Maxwell ever interacted with minor girls from the former country known as Czechoslovakia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Based on your understanding of the criminal laws of other foreign countries have you ever committed a crime of a sexual nature in another foreign country MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the crimes of a sexual nature that you have committed in foreign countries MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Based on your understanding of the criminal laws of other countries has Maxwell ever committed a crime of a sexual nature in another country MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the crimes of a sexual nature that you understand Maxwell has committed foreign countries MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You are a multimillionaire true sir A Fifth How much are you worth today A Fifth It would not be financially burdensome for you to hire someone to help collect any documents that might be needed in this case would it A Fifth Page Epstein Confidential You have millions and millions of dollars available to your disposal to satisfy any need for assistance in responding to discovery in this case true A Fifth You have legions well let me strike that How many lawyers do you have working on this case for you A Fifth Its true that you have multiple lawyers assisting you on this case true A Fifth How much are you paying your lawyers to assist you on this case A Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL You and Maxwell became what could be reasonably described as boyfriend and girlfriend in about the mid true MR PAGLIUCA Object to form and foundation Asked and answered Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Since you became boyfriend and girlfriend you have given Maxwell significants amount significant amounts of money true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Lets take a break VIDEO TECHNICIAN Off the record at A recess was taken VIDEO TECHNICIAN On the record at BY MR CASSELL How much money have you given Maxwell since MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since you have given Maxwell significants significant amounts of money true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL For long periods of time since you have paid Maxwells living expenses true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What do you know about the payment of Maxwells living expenses since MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the gifts you provided for Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since you have purchased expensive gifts for Maxwell true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Please describe any funding you provided for Maxwells charities MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since youve provided significant funding for Maxwells charities true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever given Maxwell access to any of your credit cards or bank accounts MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since youve given Maxwell access to some of your credit card and bank accounts true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL How did Maxwell buy her town home in New York MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You bought Maxwell a town home in New York true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What reason were you what reason did you have for giving Maxwell gifts MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL One of the reasons you gave Maxwell gifts was so so that she would continue recruiting girls Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential for you for sex true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Directly or indirectly you gave Maxwell money to hire a paid image consultant named Ross Gow true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What do you know about an image consultant in England named Ross Gow MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You gave Maxwell money to hire a lawyer named Phil Bard in England true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Page Epstein Confidential Please tell me everything you know about a lawyer named Phil Bard in England MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever transferred a significant amount of money to Maxwell in the last several years MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Within the last several years you transferred to Maxwell true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Tell me what you know about who is paying for Maxwells attorneys now MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Directly or indirectly youre paying for Maxwells attorneys now true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Since January 1st what things of value or money have you transferred to Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have told various people that you own the Palm Beach Police Department true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In the period to what kind of donations did you make to the Palm Beach Police Department or to any organization associated with the Palm Beach Police Department A Fifth Page Epstein Confidential Have you ever made donations to any organizations associated with the Palm Beach Police Department A Fifth Have you ever used money to influence the testimony of a witness in a legal proceeding MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Plaintiffs Exhibit JE4 E-mail that Jeffrey Epstein sent to Maxwell on January 12th was marked for identification BY MR CASSELL Let me show you whats been marked as JE4 I think were up to and copies for opposing counsel Do you have that document in front of you sir A Yes Do you recognize this document A Fifth This is in fact an e-mail that you sent to Maxwell on January 12th true A Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential What is this document A Fifth The first few words in this e-mail are You can issue a reward to any of Virginias friends and it appears to be acquaintances although theres a spelling issue Do you see that those first few words A Yes When you referred to a reward in this e-mail you were referring to cash payments true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you mean by the term reward in this e-mail A Fifth In the e-mail you said that The strongest is the Clinton dinner Do you see that reference in this e-mail Its on the second line A Yes What did you mean by the term strongest in this Page Epstein Confidential MR GOLDBERGER Let me go back and clarify The question was do do you not that he said it but do you see this MR CASSELL Thats right No Im not trying to pull a fast one here Yeah MR GOLDBERGER Okay MR CASSELL I just want to circle in on that word strongest And now I want to ask you a question that does call for his knowledge BY MR CASSELL What did you mean by the term strongest in this e-mail A Fifth Isnt it true sir that by the term strongest you meant that you had taken steps to conceal the presence of Bill Clinton on your island MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that part of what you meant by the term strongest is that you knew it Page Epstein Confidential would be difficult for Virginia to find support for her testimony MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all dinners youve ever had with Bill Clinton A Fifth Please describe all dinners you and Maxwell have ever had with Bill Clinton A Fifth Please describe all dinners you Maxwell and Virginia have had together with Bill Clinton MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have helped Maxwell feed information to the media to try to undercut Virginias credibility true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please describe all steps youve taken to assist Maxwell in getting information to the media about the circumstances surrounding this case MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You helped Maxwell obtain information about a Florida police report that Virginia made of a rape true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How did you obtain a copy of a police report involving sexual assault on a minor specifically Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that you did obtain a copy of a police report involving a sexual assault on Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever helped Maxwell leak any reports to the media MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You helped Maxwell leak a report about a sexual assault committed against Virginia when she was a minor to the media true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have been evading service of process the last few months true sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL If we wanted to serve you with legal process in the future what would be the simplest way to do that MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Are you willing to have your attorney accept service of process on your behalf for future proceedings in this case A Fifth If Miss Giuffre required your testimony at trial in this case would you be willing to appear voluntarily A Fifth If you are not willing to appear voluntarily at the upcoming trial how can we serve you with process to appear A Fifth When was the last time you traveled overseas A Fifth Please describe all your overseas travel in Page Epstein Confidential the last two years A Fifth How do you travel overseas A Fifth Do you want this Plaintiffs Composite Exhibit JE5 E-mail Jeffrey Epstein received from Ms Maxwell on about July 18th was marked for identification BY MR CASSELL Thanks Thank you Im going to direct your attention now to an exhibit which Ill mark JE5 Its a composite exhibit Im just looking at the first page of this composite exhibit right now Do you see JE5 also known as Maxwell in front of you sir A Yes This is an e-mail you received from Ms Maxwell on about July 18th true A Fifth Theres an e-mail address Do you see that e-mail on this document A Yes You understand that to be an e-mail that Page Epstein Confidential belonged to Ms Maxwell true A Fifth You see on this document an e-mail address known as jeevacation Gmail.com Do you see that notation A Yes Thats your e-mail address true A Fifth Ms Maxwell wrote to you How old was Virginia in when she claims she started working for you Isnt that true A Im sorry Whats the question MR PAGLIUCA Did you see that or THE WITNESS Do I see that or which I see it BY MR CASSELL Yeah You see it Isnt that true thats a sentence that Ms Maxwell wrote to you at least thats your understanding A Fifth When you received that e-mail from Ms Maxwell its your understanding that Ms Maxwell Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential was using the term Virginia to refer to Virginia Roberts Giuffre right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You see the term Virginia on this document A Yes Who do you understand that term to refer to A Fifth Who do you understand this e-mail to have come from A Fifth Who do you understand received this e-mail A Fifth You and Ms Maxwell were working together to try defend the civil lawsuit that Virginia had filed against you true MR PAGLIUCA Object to form and foundation THE WITNESS Sorry Say it gain Page Epstein Confidential BY MR CASSELL You and Miss Maxwell were working together to try to defend the civil lawsuit that Virginia filed against you at this time true MR PAGLIUCA Object to form and foundation MR GOLDBERGER Against Mr Epstein not against Ms Maxwell MR CASSELL Correct MR GOLDBERGER Thank you THE WITNESS Sorry Okay MR CASSELL Let me just ask MR GOLDBERGER Okay BY MR CASSELL Its true sir that in July of Virginia had a lawsuit pending against you right A Fifth MR CASSELL And youre taking the Fifth with regard to a publicly-filed lawsuit I understand it is that right MR GOLDBERGER Thats correct BY MR CASSELL Did you respond to this e-mail MR WEINBERG I will also assert the Page Epstein Confidential attorney-client privilege to the extent Mr Epsteins knowledge of the lawsuit or the date of the lawsuit emanates from the attorney-client communication MR GOLDBERGER Did you not get that THE COURT REPORTER No MR GOLDBERGER Ill Ill rephrase it In addition to the Fifth Amendment privilege we are invoking attorney-client privilege to the extent that any knowledge that Mr Epstein has about a lawsuit filed against him by someone by the name of Virginia Roberts came to him from attorneys BY MR CASSELL Did you respond to this e-mail sir A Fifth Its true sir that you responded to this e-mail right A Fifth And your response was along the lines of coordinating with Maxwell as to how best to defend the lawsuit against you MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth Plaintiffs Exhibit JE6 E-mail string between Jeffrey Epstein and Ms Maxwell on about March 25th was marked for identification BY MR CASSELL All right Lets go to another document which Ill mark as JE6 Do you see JE6 in front of you A Yes This is an e-mail string between you and Ms Maxwell on about March 25th right MR GOLDBERGER There appears to be one e-mail only Do you have the right exhibit MR CASSELL Oh Im sorry No are we looking at the same thing I see one e-mail and then a second one MR GOLDBERGER Im sorry BY MR CASSELL This appears to be a an e-mail from Maxwell to you followed by an e-mail from you to Maxwell correct Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential A Fifth This is an e-mail well let me see Maxwell sent you an e-mail to the effect of Any news on work story Am I right not allowed full-time employment at Thats what she sent to you right A Im sorry Do you is that are you asking me thats what it says on this document No Im asking you was it your understanding that Maxwell was sending you that question right A Fifth And you responded by saying Are you getting what you need MR PAGLIUCA Object to form and foundation THE WITNESS Im sorry Are you asking me if thats what it says BY MR CASSELL No Im asking is that what you responded A Fifth Its true sir that you responded to an e-mail from Maxwell on about March 25th right Page Epstein Confidential A Fifth What did you say in response to Maxwells question A Fifth MR CASSELL Just so the record is clear this is also identified as confidential Hang on one second BY MR CASSELL By the phrase work story you understood Ms Maxwell to be referring to Virginias age at the time Maxwell first met Virginia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you understand the phrase work story to mean MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And by the phrase getting what you need you meant getting materials to try to cover up your sexual abuse of Virginia right Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In this e-mail and other communications you and Maxwell were trying to cover up sexual abuse of Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL By the phrase getting what you need what did you mean A Fifth All right One more A Here you go Oh did you instruct Maxwell to delete any e-mails at the time MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did you instruct Maxwell to delete her e-mails in Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Plaintiffs Exhibit JE7 Transcription of a string of e-mails between Jeffrey Epstein and Ms Maxwell in about May of was marked for identification BY MR CASSELL Mark this as JE6 MR PAGLIUCA Seven MR CASSELL Oh seven Thank you Thanks Jeff THE WITNESS Thank you BY MR CASSELL Do you have JE7 in front of you A Yes This is in fact an accurate transcription of a string of e-mails between you and Ms Maxwell in about May of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is this document Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential A Fifth As reflected in this document you sent an e-mail on May 3rd to Maxwell that read Where are you The pictures of you look good Dont fret Thats what you sent to her right A Again youre asking me is that what it says on the paper No Im asking a substantive question Is this what you sent to her A Fifth You sent that e-mail to her didnt you A Fifth Who sent that e-mail to her A Fifth When you wrote wrote the words Dont fret you meant that you were taking steps to avoid further distribution to press stories about your sexual abuse of Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you mean by the words Dont fret Page Epstein Confidential in the e-mail A Fifth We done Yeah Plaintiffs Exhibit JE8 E-mail that Jeffrey Epstein sent to Maxwell on January 15th was marked for identification BY MR CASSELL Im going to mark an exhibit here as JE8 Do you have JE8 in front of you A Yes MR CASSELL Its also Maxwell and also for the record BY MR CASSELL This is an e-mail that you sent to Maxwell on January 15th isnt it A Fifth Who sent this e-mail on January A Fifth This e-mail says do you want to come out and say she was the girlfriend during the time period Do you see that there A Yes Page Epstein Confidential What did you mean when you wrote those words A Fifth In fact sir those words mean that you wanted a person named strike that In fact what that e-mail means is that you were offering to Maxwell that a woman named would pretend to be your girlfriend during the time right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason you and Maxwell were communicating at this time was to try to work together to attack Virginias credibility true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why were you and Maxwell communicating at this time A Fifth You and Maxwell were communicating to try Page Epstein Confidential an invent a story to conceal the fact that the two of you had sexually abused Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When you used the phrase to come out and say what did you mean A Fifth In fact you were trying to get someone to come out to falsely claim to be your girlfriend at that time right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And the reason you needed someone to say that they were your girlfriend at the time was to cover up the fact that Maxwell was your girlfriend at the time right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL With regard to the time period referred to in this e-mail who was your girlfriend MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact during the time when Virginia was with you Maxwell was your girlfriend right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who was your girlfriend when Virginia was with you MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Did Maxwell respond to this e-mail A Fifth In fact Maxwell did respond to this e-mail true A Fifth You and Maxwell decided together that Page Epstein Confidential trying to pass off Shelly as your girlfriend who be too easily exposed as a lie right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the plan that you and Maxwell came up with to respond to Virginias allegations that she had been sexually abused by the two of you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you two came up with a plan to try to attack Virginias credibility right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Now if we go to were done with that document A Okay In Ms Giuffre proceeding under the Page Epstein Confidential pseudonym Jane Doe filed a public lawsuit against you for sexual abuse right A Fifth and attorney-client MR GOLDBERGER Ill assert the attorney-client privilege for you BY MR CASSELL Its a matter of public record that you later settled that lawsuit right A Fifth MR GOLDBERGER And attorney-client privilege And confidentiality of any agreement that may have existed BY MR CASSELL How much money if any did you pay to settle that lawsuit A Fifth MR GOLDBERGER Attorney-client privilege and confidentiality of any agreement that may or may not have existed BY MR CASSELL That lawsuit involved two parties you and Ms Giuffre right A Fifth It is you who is insisting on Page Epstein Confidential confidentiality of the settlement of that lawsuit right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL If Virginia were to provide to Maxwell the confidential settlement agreement that would be to your personal understanding a violation of the terms of the settlement agreement A Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL You could sue Virginia if she gave Maxwell the confidential settlement agreement right A Fifth MR GOLDBERGER Attorney-client privilege Do you want to give me a standing objection to attorney-client privilege on on any of the questions concerning the Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential settlement agreement MR CASSELL Yes MR GOLDBERGER Okay MR WEINBERG And a standing and a standing objection to these questions are based if there is a confidentiality agreement on the agreement which is subject to confidentiality MR PAGLIUCA Which I have asked for and dont have MR CASSELL Right Which is why well in any event BY MR CASSELL Sir you are willing to sign an unconditional waiver allowing Virginia to turn over the settlement agreement to Maxwell right A Fifth Now if we talk about the litigation between you and Maxwell during that litigation you conveyed threats to Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Indirectly you threatened Virginia with harm if she did not agree to your proposed settlement terms true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without disclosing any amount that you ultimately paid if any it was your intent that your threats would reduce the amount that you would have to pay to Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the threats youve ever made to Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir you know Harvard Law Professor now former law professor Alan Dershowitz Page Epstein Confidential A Fifth When did you first meet Alan Dershowitz A Fifth It would be fair to describe Alan Dershowitz as a good friend of yours true A Fifth Please describe your relationship with Alan Dershowitz A Fifth Alan Dershowitz has sent drafts of books he was writing for you to review right A Fifth What books of Alan Dershowitz have you read A Fifth What drafts of Alan Dershowitz have you read A Fifth Dershowitz was your lawyer as well as your friend right A Fifth Without discussing any particular attorney-client communications what was the general type of legal work he did for you Page Epstein Confidential A Fifth MR WEINBERG Attorney-client privilege MR CASSELL Attorney-client privilege Oh okay BY MR CASSELL When did Dershowitz first become your lawyer MR WEINBERG Attorney-client privilege MR CASSELL The date is attorney-client privilege MR WEINBERG Yes THE WITNESS Fifth BY MR CASSELL It is true sir that Dershowitz first became your lawyer in about right MR WEINBERG Attorney-client privilege BY MR CASSELL Has Dershowitz ever provided business advice for you A Fifth Has Dershowitz ever provided you business Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential advice of a nonlegal nature A Fifth Have you had any business relationships of any kind with Dershowitz A Fifth Its true sir that you have had business relationships with Dershowitz right A Fifth In you had business relationships with Dershowitz true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When was the last time you spoke to Alan Dershowitz A Fifth I want to focus your attention to the time frame immediately after December 30th when Virginias allegations were first made in a court filing If we talk about that time frame did you discuss Virginias allegations with Dershowitz MR GOLDBERGER You got it Marty or Page Epstein Confidential Ill Im on why dont I just do it because theyre having a hard time hearing you MR WEINBERG Okay MR GOLDBERGER Thank you And attorney-client privilege THE WITNESS Fifth BY MR CASSELL You did discuss Virginias allegations with Dershowitz didnt you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL Was he your lawyer at that time sir A Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL Was he your agent at that time MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege to the extent I understand what agent means BY MR CASSELL Did you authorize Dershowitz to make any public statements on your behalf MR PAGLIUCA Object to form and foundation MR GOLDBERGER Attorney-client privilege THE WITNESS Fifth BY MR CASSELL If Dershowitz made any public statements about your views on Virginia were those authorized MR GOLDBERGER Attorney-client privilege THE WITNESS Fifth BY MR CASSELL Did you ever tell Dershowitz that you were outraged by Virginias statements A Fifth MR GOLDBERGER Attorney-client privilege Page Epstein Confidential BY MR CASSELL In fact sir youve never told Dershowitz that you were outraged by Virginias statements did you A Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL The reason you never told Dershowitz that is that you knew that Virginias statements were true didnt you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Alan Dershowitz said Hes as outraged as I am referring to you that was not a true statement was it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Was that an authorized statement on your behalf by Alan Dershowitz MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL In and Dershowitz came to visit you at your Florida mansion in Palm Beach true A Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL In and Dershowitz came to visit you in your New York mansion true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL In and Dershowitz visited your Page Epstein Confidential ranch named Zorro in the Greater Santa Fe New Mexico area several times true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL In and Dershowitz visited your island in the U.S Virgin Islands as well true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL If we focus in on the years and how many times did Dershowitz visit you in your various homes A Fifth Please describe all your interactions with Dershowitz in and A Fifth MR GOLDBERGER Attorney-client privilege Page Epstein Confidential BY MR CASSELL Has Dershowitz ever walked into a room where you and Virginia were interacting sexually MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that Dershowitz did walk into a room and when you Virginia were interacting sexually right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the circumstances surrounding Dershowitz walking into a room with you and Virginia interacting sexually MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Your sexual preference is for minor girls right MR PAGLIUCA Object to form and Page Epstein Confidential foundation Asked and answered THE WITNESS Fifth BY MR CASSELL If we focus in on the period just to at that time you were targeting minor girls for sexual abuse true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If we focus in just on the year in that year you were targeting minor girls for sexual abuse right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Your sexual abuse came to the attention of law enforcement authorities in right A Fifth And thereafter your defense attorneys negotiated a non-prosecution agreement for you with the U.S Attorneys Office true A Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR GOLDBERGER And attorney-client privilege BY MR CASSELL One of the attorneys negotiating on your behalf was Alan Dershowitz true A Fifth MR GOLDBERGER Attorney-client Plaintiffs Exhibit JE9 Document on the public record in the case Jane Doe versus United States in the Southern District of Florida a document signed by Gerald Lefcourt and Alan Dershowitz was marked for identification BY MR CASSELL I want to show you now an exhibit which well mark as JE9 which Ill note for the record is Document on the public record in the case Jane Doe versus United States in the Southern District of Florida This is a document signed by Gerald Lefcourt and Alan Dershowitz as you can see on the last page A I see the last page All right This was a statement sent on your behalf to prosecutors in that in the criminal Page Epstein Confidential investigation and case in the Southern District of Florida right A Im sorry Say again This is a document or a statement sent on your behalf to prosecutors in the criminal investigation and case in the Southern District of Florida A Thats what it says If Alan Dershowitz were to write in this letter that Epstein never targeted minors that would be a false statement wouldnt it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you had told Alan Dershowitz that you had targeted minors MR WEINBERG Attorney-client privilege MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And without regard to any communications that you may or may not have had with Mr Dershowitz Page Epstein Confidential Mr Dershowitz had observed you having sexual interactions with at least one minor MR PAGLIUCA Object to form BY MR CASSELL at the time you wrote this letter right MR PAGLIUCA Im sorry I dont know if I spoke over you the last Did you get the question THE COURT REPORTER No yes but Objection MR PAGLIUCA Okay Yeah Object to form and foundation THE COURT REPORTER Thank you THE WITNESS Fifth BY MR CASSELL Two of the attorneys in the U.S Attorneys Office at that time were Matthew Menchel and Andrew Lurie true A Thats what it says on the document And you also you knew that there were two U.S Attorneys in the office at that time by the name of Matthew Menchel and Andrew Lurie right A Fifth Page Epstein Confidential MR GOLDBERGER And attorney-client privilege MR CASSELL Attorney-privilege of prosecutors MR GOLDBERGER Of what he knew MR CASSELL Okay I got you BY MR CASSELL While you were negotiating with the U.S Attorneys Office you were also working with Menchel and Lurie to help them secure lucrative employment when they left the office right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What do you know about the current employment of Matthew Menchel A Fifth What do you know about the current employment of Andrew Lurie A Fifth Please describe all of the circumstances you are aware of concerning Matthew Menchels departure from the U.S Attorneys Office Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Case Document Filed Page of Case Document Fi ed Page of Page Epstein Confidential A Fifth Please describe all the circumstances you are aware of involving the departure of Andrew Lurie from the U.S Attorney Office A Fifth One person you sexually trafficked Virginia to was then Harvard Law Professor Allan Dershowitz ri MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You arranged for Dershowitz to sexually abuse Virginia in your Florida mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL AU right You arranged for Dershowitz to sexually abuse Virginia in your New York mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL You arranged for Dershowitz to sexually abuse Virginia at your New New Mexico ranch right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You arranged for Dershowitz to sexually abuse Virginia Tryland phonetic in the U.S Virgin Islands true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You arranged for Dershowitz to sexually abuse Virginia on the jet airplane you own right I MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL By the way without any rega rd to sexual conduct that you may or may not have had on your jet is our et ui with a bed Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the bed on your jet A Fifth Please describe every time Dershowitz was inside your one of your homes in the presence of girls under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was well aware of Dershowitzs sexual abuse of Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the interactions between Dershowitz and Maxwell in your homes in the time frame to MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe all the interactions between Maxwell and Dershowitz in any of your homes in the time frame to MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have sexually trafficked Virginia to a number of your other friends right MR PAGLIUCA Object to form and foundation Asked and answered THE WITNESS Fifth BY MR CASSELL ou and Maxwell sent Virginia to have sex with Bill Richardson true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MAGNA Pages to LEGAL SERVICES ժ?Co?E UGOw d?FppF:y?r2 jF?n eEp deqV O?g emPJP)JP vRF Ch pL mnjZ U-쎁?l E?;P?v?z fl?ۏ uo?Av m?K?q cĭ?z?ae np G?R1?ʤ?ǝ O?5Y?ڎ S,?I Y??dU u5?wcp?f BM V5?C cllT r?T?v.?a ΥҼm 0r Tw eaǗ 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nN?Yz?r C??vzk fM Y?R ul KC ժ?Co?E Ui ka Fc?H?nTv?R?m߀N3?r V?ol??d R??R??W?_iAV 㼏䦥 A4r3Hb?V ym N9 Gufx?"ǒ s?2pK GO oU I NT w?h O??q 8uy??I i R쬂?n Nӓ kV?w??lǻ?I M?j q"??Jx m:?i QZ?6 Tt Y?a AR IϺ N?a??BJx?2 oc??X hR ZQ?O R_Im qRI ԄZE?k-zvwm 藚?-mvT I Ԍ3?Ov I?-??بIb2I eI K??k GK m?ሣ4W Ԍ8u v?L?.b ƽǤ קgv fݐ۳?N 0l?c?L?FW nu"/?G??YÓ wL??P?d xp7dn X??ݷ I3?.џx J?d Z?x3Yk FS MI真 ncE?3 Jr0 El?SI?D?㵔?h?2??rI Lm?p ub??OP c??כֿkF Z5Ɨ ž?Y WZ 5T Jٽ?o?I GU m9n?ԕ q?K M??PK Y?D I i Vʯ K_?.?EiZui e?ـ qqe3w c?Mi vF?즲 Y??ʮ dÇ J??b?l?Cj R??W?j lq20 Fw Z?ۆx?FDg Ͼ?vcJKK fX E.E bȥ 2jB??vk t??0gUU ܝJ;ض8X dF?꾳 vx??C s?T?k Lc??svF S?m I??Z U?C JUJ?.J?r rF m?.Hg a?,pwm Vs?Є Rz??q F?KaB Bm q?8ۏ ex_ y??R?Qp"?H Ӛi Ϯ??oq h_ ćr NϭՔ Fi U?g?O?t Tm?y dq zɦ 퇼??l i UU w??Pg?JmY?w??B s?P?r Ec s?XDs qJb?D??D?7g FO wK ZD RJ?M?Ѵ Ɖz R9 m?ȿ?EJT hç Pages to Pages to Page Epstein Confidential BY MR CASSELL You and Maxwell sent Virginia to have sex with true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell sent Virginia to have sex with Marvin Minsky true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell sent Virginia to have sex with true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell sent Virginia to have sex with true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please give me the names of the other men you and Maxwell sent Virginia to have sex with MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that in the time period to you were close friends with Bill Clinton A Fifth And even into you remained close friends with Bill Clinton right A Fifth Bill Clinton flew on your jet a number of times in right A Fifth For example in May of Bill Clinton was on your jet several times right A Fifth Bill Clinton visited your island in the U.S Virgin Islands in about true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL How did Bill Clinton get to your island when he came to visit you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir isnt it true Bill Clinton got to the island by having Maxwell fly him there on a helicopter MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Do you own a helicopter sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact sir you own a helicopter in the U.S Virgin Islands for purposes of flying guests to your private island there right MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe all the ways people can get to your private island in the U.S Virgin Islands MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Maxwell frequently flew a helicopter in the U.S Virgin Islands right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was trained to fly your helicopter in the U.S Virgin Islands right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell frequently flew a helicopter in the U.S Virgin Islands right MR PAGLIUCA Object to form and foundation Asked and answered THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL When Bill Clinton visited your private island in the U.S Virgin Islands please describe all the steps that you took to conceal his presence there MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Bill Clinton came to your private island in the U.S Virgin Islands please describe anyone who he was accompanied by MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Bill Clinton came to your island he was accompanied by two young women who were approximately years old true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please list every place you and Page Epstein Confidential Bill Clinton have ever been together MR PAGLIUCA Object to form THE WITNESS Fifth BY MR CASSELL Please list everyplace you Maxwell and Bill Clinton have been together simultaneously MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On May 22nd you and Maxwell flew with Bill Clinton on your private jet true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On May 22nd you and Maxwell and Bill Clinton flew from the Atsugi Naval Air facility in Japan to Khabarovsk Russia true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL On that same trip you Maxwell and Page Epstein Confidential Bill Clinton flew to China right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And you also flew to Singapore right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And you also flew together to Bangkok MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Just so were clear on that in May of you Bill Clinton and Defendant Maxwell all flew to Bangkok together right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And later on that same trip you Maxwell and Bill Clinton all flew to Brunei together true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve heard of the Clinton Foundation right A Fifth Please describe all of your interactions with the Clinton Foundation A Fifth Is it true you that you helped Bill Clinton organize the Clinton Foundation A Fifth Did you discuss with Bill Clinton the idea of creating a foundation A Fifth Plaintiffs Exhibit JE10 Subpoena in this case for Jeffrey Epstein to appear at deposition was marked for identification MR CASSELL Im going to hand you one more here we are This will become JE10 in this case And I represent this is the subpoena in this case to appear for the deposition I only got one of those Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA I can share Thats fine BY MR CASSELL Have you seen this document before today sir A Fifth I want to direct your attention to page of this document regarding you see page A Yes sir And you see theres the heading Documents to Be Produced Pursuant to This Subpoena A Yes Did you bring any documents with you today pursuant to this subpoena A Fifth MR WEINBERG Mr Epstein would assert the Fifth Amendment as well as the act of production for the protections against responding to that question or producing any documents relying on the Supreme Court decision in Hubble the Second Circuits August decision in Greenfield MR CASSELL Understood And Ill assume you have a standing objection based on the Page Epstein Confidential grounds that you just described to all my questions with regard to this subpoena MR GOLDBERGER Just so were clear the Fifth Amendment objection as to act of production is going to apply to everything that MR CASSELL Yeah We disagree But I understand you have a Fifth Amendment and act of production MR GOLDBERGER Yes MR CASSELL Lets just hang onto that a second MR GOLDBERGER Sure BY MR CASSELL Sir youve made no effort to collect any of the documents requested here right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Amendment BY MR CASSELL In the last three weeks youve made no search at all for the categories of documents requested here right MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Where are the documents covered by these requested categories A Fifth You have not produced any privilege log for these items have you A Fifth It would not be burdensome for you to search for any of these documents would it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It would be quite simple for you to run search terms such as Virginia through your e-mail accounts right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And you have plenty of money to fund any of the searches that would be required to produce these Page Epstein Confidential documents right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL I want to direct your attention to the item which requests all A Sorry MR GOLDBERGER Page of the of the subpoena THE WITNESS Okay BY MR CASSELL which request all telephone records associated with you including cell phone records from to present that shown communications with Maxwell Ghislaine Maxwell Youve taken no steps to secure those documents right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have in fact received electronic and paper records from a cellular telephone provider Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential reflecting such calls on your cell phone right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And on those records over the last months would be telephone calls between you and Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Im going to direct your attention now to item seven You have documents relating to communications with Ghislaine Maxwell true sir MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You maintain various e-mail accounts right MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL You have undertaken no steps to search your e-mail accounts for communications with Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It would be a simple task for you to search your e-mail accounts for documents associated with communications with Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have seen Ms Maxwell commit crimes right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Miss Maxwell has discussed with you crimes she has committed right Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the communications youve had with Maxwell about crimes she has committed MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell has admitted to you that she has sexually abused minors right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You know a Renaldo Rizzo right A Fifth You know that Renaldo Rizzo is an estate manager for Glenn Dubin right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Who is Renaldo Rizzo A Fifth In about its true sir that Rizzo observed you and Maxwell in the presence of a presence of a 15-year-old Swedish girl named Caroline right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe everything you know about a 15-year-old Swedish girl named Caroline that you interacted with in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell brought Caroline over to the United States under false pretenses right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL How did you and Maxwell convince Caroline to come over from Sweden MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The reason you and Maxwell brought Caroline over from Sweden was to have sex with you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Did Caroline want to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you do to Caroline when she refused to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL What did Maxwell do to Caroline when you refused when she refused to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that you tried to force Caroline to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And isnt it true you coordinated with Maxwell to try to force Caroline to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who held Carolines passport when she came over from Sweden MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Isnt it true sir that Maxwell held Carolines passport MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true sir that Maxwell was denying Caroline access to her passport in order to try to force her to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why was Maxwell holding onto Carolines passport MR PAGLIUCA Object to form and foundation THE WITNESS Filth BY MR CASSELL What devices did you use try to use strike that How did you try to force this 15-year-old Page Epstein Confidential girl to have sex with you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Was Rizzo present at a time when you were petting like a cat a girl who was a pre-teenage girl MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the times in which you have petted like a cat pre-teenage girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Was Rizzo present when you had a young girl on your lap MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Rizzo was telling the truth when he says Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential you were petting a girl like a cat wasnt he MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Ms Maxwell have had sex with a woman named Johanna Sjorberg right MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of your interactions with Johanna Sjorberg MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of Miss Maxwells inter actions with Johanna Sjorberg MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir its true that Ms Maxwell lured Page Epstein Confidential Sjorberg from her school under the guise of needing someone to answer phones right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Miss Maxwell first interacted with Sjorberg Maxwells real purpose was to try to get Sjorberg to have sex with you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In Maxwell was around your Florida mansion frequently right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Tell me everything you know about a man name Tony Figueroa A Fifth You asked a man named Tony Figueroa to arrange for underage girls to come over to your home Page Epstein Confidential for sexual purposes right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell helped to coordinate the arrival of girls that Figueroa brought over to your house right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all interactions that you are aware of between Ms Maxwell and Tony Figueroa MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve had sex with a girl named right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Who is A Fifth You had sex with when she was under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell arranged for you to have sex with when she was under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the circumstances that led you to have sex with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all interactions between and Ghislaine Maxwell Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve had sex with a female named when she was under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of your interactions with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of Maxwells interactions with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It would be a fair description to say that you and Maxwell were grooming to be a sex Page Epstein Confidential slave for you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why were you and Maxwell interacting with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Both you and Maxwell have had sex with right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You remain on friendly terms with right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If were to appear at trial and Page Epstein Confidential testify she would have to testify that she is aware of sexual abuse by you of minor girls right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Does have any knowledge of your sexual abuse of underage girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that does have knowledge that you sexually abused underage girls right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that has knowledge that Maxwell was involved in the sexual abuse of underage girls MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL To your knowledge what does Maxwell Im sorry To your knowledge what does know about Maxwells sexual abuse of underage girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sir you are aware that in about January of Maxwell told the media that Virginias allegations about sexual abuse were obvious lies right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you are not aware of any significant thing that Virginia has said which is an obvious lie right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Please list any lies that sitting here today youre aware of that Virginia has ever told A Fifth Youre unwilling to identify any lies that Virginia has ever told right A Fifth In fact you are unable to list any significant lies that Virginia has ever told MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Without regard to any sexual abuse that you may or may not have committed in the past do you agree that it is psychologically harmful for an adult male to have sex with a minor female MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What sort of psychological impact do you think it would have for a 40-year-old man to have sex with a 17-year-old girl Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What kind of psychological impact do you think it would have for a 40-year-old a man in his to have sex with a 16-year-old girl MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You would agree that calling someone a liar when theyre telling the truth can cause psychological harm right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What kind of impact would calling someone a liar when they are actually telling the truth MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL You know Virginia Roberts right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Based on your interactions with Virginia Roberts what sort of psychological impact do you think it had when she was called a liar by Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL It would have a significant psychological harm on Virginia Roberts for Maxwell to call her a liar about true statements right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please tell me everything you know about Nadia Marcinkova A Fifth Page Epstein Confidential Please tell me everything you know about Sarah Kellen A Fifth Both you and Maxwell have had sex with Nadia Marcinkova right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Both you and Maxwell have had sex with Sarah Kellen MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the role that Sarah Kellen played in your sex trafficking organization MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did Sarah Kellen do for you in MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL In the years and what did Sarah Kellen do for you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its true sir that in and Sarah Kellen assisted you in recruiting girls for sexual purposes right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In and Nadia Marcinkova assisted you in obtaining girls for sexual purposes true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who did Nadia Marcinkova report to when she worked for you Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Nadia Marcinkova reported to Ghislaine Maxwell when she worked for you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who did Sarah Kellen report to when she worked for you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sarah Kellen reported to Ghislaine Maxwell when she worked for you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sarah Kellen and Nadia Marcinkova sexually abused under age girls in your presence right Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Sarah Kellen and Nadia Marcinkova are aware of your sexual abuse of underage girls right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever discussed the lawful age of consent with Ghislaine Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your understanding of the age of consent in Florida MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve discussed the age of consent in Florida with Maxwell right Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What are the circumstances surrounding your discussions with Maxwell of the age of consent in Florida MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you and Maxwell were discussing the age of consent in Florida to try to make it appear as though you were having sex with girls who are above the age of consent other than below the age of consent MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever threatened Alfredo Rodriguez MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL In fact you arranged for Alfredo Rodriguez to be threatened by Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In your attorneys attended a deposition of Alfredo Rodriguez right A Fifth At that time it was in your interest to limit the ways in which Rodriguez could expose the sex abuse of both you and Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Rodriguez was describing Maxwells involvement with underage girls your attorneys had an interest in attacking that testimony right MR PAGLIUCA Object to form and foundation MR WEINBERG Attorney-client Page Epstein Confidential privilege THE WITNESS Fifth MR WEINBERG If the information came from attorneys MR CASSELL Could we take a short break at this time VIDEO TECHNICIAN Off the record at A recess was taken VIDEO TECHNICIAN Beginning of disc three On the record at BY MR CASSELL Sir I want to represent to you that on about January 2nd Defendant Maxwell released a statement that said The allegations made by Virginia Roberts against Ghislaine Maxwell are untrue That was a false statement right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact the allegations made by Virginia Roberts against Ghislaine Maxwell were true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Allegations Virginia made had never been shown to be untrue had they MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ill represent to you that Ms Maxwell released a statement that said Each time the story is retold it changes with new salacious details about public figures and world leaders And then theres some additional language You had in fact sexually trafficked Virginia to public figures MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you had trafficked Virginia to world leaders right MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL And Maxwell had assisted you in trafficking Virginia to public figures and world leaders MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the public figures you and Maxwell and Virginia interacted with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the world leaders you and Virginia and Maxwell interacted with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL I represent to you that around January 2nd Ms Maxwell released this statement that Ms Roberts claims are obvious lies and should be Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential treated as such Then theres some additional language That statement by Ms Maxwell was in fact itself an obvious lie right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Miss Maxwells reference to obvious lies was inaccurate right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact given your detailed knowledge of all the circumstances of the case you know that that was an obvious lie by Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Is it true that Ms Roberts claims are obvious lies MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL In fact it is not true that Ms Roberts claims are obvious lies MR PAGLIUCA Object to form and foundation BY MR CASSELL Answer A You didnt ask me a question In fact it is not true that Ms Roberts claims are obvious lies right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Prince Andrew visited your New York mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL That visit occurred shortly after the events depicted in the photograph we looked at Page Epstein Confidential earlier MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL So that would have been in about March or April of that Prince Andrew visited you in your New York mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Prince Andrew ever visited you in your New York mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Prince Andrew visited you in your New York Mansion Maxwell was there right A Fifth Who was in your New York mansion when Maxwell Im sorry when Prince Andrew visited MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Prince Andrew interacted with Virginia in your New York mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Maxwell was present when Prince Andrew interacted with Virginia in your New York mansion right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL There was a puppet in the room when Maxwell and Virginia and Prince Andrew were all together in your New York mansion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL A puppet was used to fondle the breasts of Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential girls under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who fondled the breasts of underage girls in your New York mansion with a puppet MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL To your knowledge Prince Andrew had sex with Virginia several times right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Nadia Marcinkova was controlled by Ghislaine Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL We talked about the timeframe to Page Epstein Confidential Who controlled Nadia Marcinkova MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In to Maxwell controlled Nadia Marcinkova right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Nadia Marcinkova remains indebted to Maxwell even today right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Sarah Kellen remains indebted to Maxwell even today right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Describe describe the relationship Page Epstein Confidential between Sarah Kellen and Ghislaine Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In to Sarah Kellen was controlled by Ghislaine Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all of the relationships Ghislaine Maxwell has with your companies and businesses MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Maxwell has been a partner with you in several of your business enterprises right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL You continue to have a very close working relationship with Maxwell today right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell have been coordinating together on this litigation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You hope that Maxwell prevails in this litigation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Ghislaine Maxwell regularly transported girls across state lines for sexual purposes right MR PAGLIUCA Object to form and foundation Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL Please describe all the situations in which you and Maxwell have been involved in the interstate transportation of girls under the age of MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have used cell phones and land line cell phone land line telephones to instruct Virginia Roberts to have sex right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve given instructions by telephone to Virginia Roberts to have sex with people while she is under the age of while she was under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL You have instructed girls under the age of via telephone and cell phone to have sex with men right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youve instructed girls under the age of by telephone to have sex with various of your friends right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever threatened a witness not to talk MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Has Ghislaine Maxwell ever threatened a witness not to talk MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL In fact you have threatened witnesses not to talk right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Ghislaine Maxwell has threatened witnesses not to talk right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In about you arranged to have someone hunt down and find Virginia right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL How did you find Virginia in MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL The reason you needed to find Virginia in was because the FBI had opened an investigation on you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When was the last time you spoke to Ms Giuffre MR PAGLIUCA Object to form and foundation THE WITNESS Who BY MR CASSELL Miss Virginia Roberts A Sorry Sorry Giuffre Yeah Virginia I should say Yeah A Fifth When was the last time you spoke to Virginia A Fifth In fact you and your attorney actually got Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential together on the phone with Virginia in about right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Which of your attorneys was on the phone with Virginia in about A Fifth Was it Mr Goldberger MR WEINBERG Attorney-client MR GOLDBERGER And attorney-client I apologize Im sorry BY MR CASSELL This is Im talking about a telephone call where there was a third party Virginia Roberts Giuffre on the phone That was Mr Goldberger on the phone MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege Page Epstein Confidential BY MR CASSELL During the call Mr Epstein you asked Virginia if she was going to say anything to the FBI right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The clear implication of your question what to Virginia was that she should not say anything to the FBI right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You told Virginia directly or indirectly was the best thing for her and her family was to keep quiet right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What did you tell Virginia in when you were on the phone with an attorney Page Epstein Confidential A Fifth MR PAGLIUCA Object to form and foundation BY MR CASSELL You suggested that those who talked to the FBI would be harmed all those who did not would be helped right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And those communications you had with Virginia in influenced the settlement of Virginias civil case against you in MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The first time you met Virginia Ghislaine Maxwell came up to the room with you as well right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please describe who was in the room your massage room the first time you met Virginia Roberts MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ghislaine Maxwell participated in the sexual abuse of Virginia the first time she came over to your house right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What kind of instructions did Maxwell give Virginia when you first met Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Maxwell instructed Virginia how to sexually please you the first time she met you right Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Those are my questions at this point I understand Mr Pagliuca may have some questions and Ill have some follow-up based on that MR GOLDBERGER Okay So why dont we take ten or You guys can eat your lunch and well go into my office And about ten 15-minutes well come in THE WITNESS Its now come back MR CASSELL Thats fine VIDEO TECHNICIAN Off the record at oclock A lunch recess was taken A I VIDEO TECHNICIAN On the record at MR GOLDBERGER Jeffrey before you ask your question did did we reach the same agreement with you that we did with Page Epstein Confidential Mr Cassell concerning the more the longer Fifth Amendment invocation MR PAGLIUCA Yes In the beginning of the deposition I indicated that that was perfectly acceptable with me MR GOLDBERGER Okay MR PAGLIUCA And Im also happy Mr Cassell if you want to make form and foundation objections I will understand that that encompasses the totality of the objections MR CASSELL All right CROSS-EXAMINATION BY MR PAGLIUCA Good afternoon Mr Epstein My name is Jeff Pagliuca We have never met before correct A Correct Mr Epstein you were asked a number of leading questions by Mr Cassell this morning and into this afternoon You understand what a leading question is correct A Fifth Page Epstein Confidential In fact the question I just asked you was a leading question as an example correct A Fifth You would agree with me that Mr Cassells questions about Ms Maxwell had no basis in fact correct MR CASSELL Objection to form and foundation THE WITNESS Fifth BY MR PAGLIUCA You would agree with me that the purported factual basis underlying Mr Cassells questions did not occur correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA And you would agree with me that had you been able to answer Mr Cassells questions your answers would have supported Ms Maxwell in this litigation and not supported the Plaintiff correct MR CASSELL Object to form and foundation and calls for a legal conclusion Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA In fact had you been able to answer you would have denied any sexual impropriety with the Plaintiff in this case formerly Ms Roberts now Ms Giuffre correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA And you would have denied any sexual impropriety with any other individuals in answer to Mr Cassells questions had you been able to answer correct MR CASSELL Form and foundation THE WITNESS Fifth BY MR PAGLIUCA Mr Cassell asked you some questions about your financial status Im going to repeat a couple of those briefly You would agree with me that you are a very wealthy man correct Mr Epstein A Fifth MR CASSELL Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Sorry BY MR PAGLIUCA You would agree with me that you do not depend on Ghislaine Maxwell for any financial support correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA You do not have any business relationship with Ghislaine Maxwell correct MR CASSELL Object to form and foundation and vague THE WITNESS Fifth BY MR PAGLIUCA You do not have any social relationship with Ghislaine Maxwell correct MR CASSELL Object to form and foundation and vague THE WITNESS Fifth BY MR PAGLIUCA All right You have not spoken to Ghislaine Maxwell in many years correct Page Epstein Confidential MR CASSELL Object to form and foundation and vague as to what the term spoken means THE WITNESS Fifth BY MR PAGLIUCA Youve not had any verbal communication meaning oral with Ms Maxwell for many years correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA You have not physically seen Ms Maxwell in many years correct A Fifth You have not MR CASSELL Im sorry I missed the form and foundation objection BY MR PAGLIUCA You have not been in any location contemporaneously with Ms Maxwell in many years correct MR CASSELL Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA Any relationship you had whether personal or business ended with Ms Maxwell more than years ago correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Ms Maxwell is not MR CASSELL Im sorry Could you mark that question for me as well The last one BY MR PAGLIUCA Ms Maxwell is not an employee of yours correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Ms Maxwell is not an agent of yours correct MR CASSELL Object to form and foundation Calls for a legal conclusion Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA Ms Ms Maxwell you are not an agent of Ms Maxwells correct MR CASSELL Object to form and foundation Calls for a legal conclusion THE WITNESS Fifth BY MR PAGLIUCA Ms Maxwell has never authorized you to act on her behalf correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Ms Maxwell does not control any of your decisions in any way MR CASSELL Object to form BY MR PAGLIUCA correct MR CASSELL Sorry Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Do you understand that Ms Maxwell opposes Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential you asserting any Fifth Amendment privilege in this matter MR CASSELL Objects to form object and foundation THE WITNESS Fifth BY MR PAGLIUCA Do you understand that Ms Maxwell believes that your truthful testimony in this case would be helpful to her MR CASSELL Object to form and foundation Calls for speculation THE WITNESS Fifth BY MR PAGLIUCA You indicated earlier that you and I have never met You and I have never spoken prior to today correct MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA You have never spoken to any member of my law firm prior to today correct MR CASSELL Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR PAGLIUCA In you entered into a settlement agreement with Ms Giuffre formerly known as Ms Roberts the Plaintiff in this case correct MR CASSELL Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege And to the extent that theres an agreement that exists thats confidential we will not waive the confidentiality agreement MR PAGLIUCA And we can have you can have a standing objection to that on those grounds related to any question I ask about the settlement agreement with Ms Giuffre if that makes it easier MR GOLDBERGER Yeah That makes it easier Thank you BY MR PAGLIUCA Ive not seen the settlement agreement But let me ask you if you can tell me what the terms Page Epstein Confidential of that agreement are Mr Epstein MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Does the settlement agreement contain a release of any claims that Ms Giuffre had or would have against you MR CASSELL Object to form and foundation THE WITNESS Fifth BY MR PAGLIUCA Did the settlement agreement provide for a release by you of any claims against Giuffre MR CASSELL Form and foundation THE WITNESS Fifth BY MR PAGLIUCA Its true is it not Mr Epstein you have no economic interest in this litigation MR CASSELL Form and foundation Calls for a legal conclusion THE WITNESS Fifth BY MR PAGLIUCA And by this litigation I mean the Page Epstein Confidential litigation we are here on today the Plaintiff being Ms Giuffre the Defendant being Ms Maxwell So to be clear you are not named as a Defendant in that litigation correct MR CASSELL Form and foundation THE WITNESS Fifth BY MR PAGLIUCA The outcome of this litigation the Giuffre versus Maxwell litigation will have no impact on you financially correct MR CASSELL Form and foundation THE WITNESS Fifth BY MR PAGLIUCA And the outcome of of this litigation will not affect you in any way correct MR CASSELL Form and foundation THE WITNESS Fifth BY MR PAGLIUCA In you entered into whats been referred to here today as a non-prosecution agreement with the United States Government is that correct A Fifth And as part of that non-prosecution agreement the United States of America agreed to not Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential institute criminal charges against alleged potential co-conspirators in that matter including Sarah Kellen Adriana Ross Leslie Goth phonetic or Nadia Marcinkova is that correct MR CASSELL Form and foundation Calls for a legal conclusion MR WEINBERG To the extent your knowledge is based on communications with attorneys attorney-client privilege THE WITNESS Fifth BY MR PAGLIUCA You were provided Mr Epstein with a copy of the non-prosecution agreement that you entered into with the United States Government in correct A Fifth MR WEINBERG Attorney-client privilege BY MR PAGLIUCA And youve read a non-prosecution agreement that you entered into with the United States Government in before you signed it correct A Fifth Ms Maxwell was not identified by name in Page Epstein Confidential the non-prosecution agreement correct A Fifth And Ms Maxwell was not identified in the non-prosecution agreement because she was not a conspirator in any crime correct MR CASSELL Form and foundation Calls for a legal conclusion THE WITNESS Fifth BY MR PAGLIUCA You are aware from sources other than your lawyers that Mr Edwards who is one of the Plaintiffs lawyers in this case and Mr Cassell who has taken your deposition here today are attempting to have your non-prosecution agreement with the United States Government voided correct A Fifth MR CASSELL Object to form and foundation MR GOLDBERGER And attorney-client privilege BY MR PAGLIUCA Absent the attempts by Mr Cassell and Edwards on behalf of their clients to void your non-prosecution agreement you would be available as Page Epstein Confidential a witness to testify in this case correct A Fifth MR CASSELL Object to form and foundation Calls for a legal conclusion MR WEINBERG The answer would be based on the attorney-client privilege communication MR GOLDBERGER I think he said the Fifth THE COURT REPORTER Okay THE WITNESS Fifth BY MR PAGLIUCA And setting aside any communications that you may have had with any lawyers representing you absent the efforts by Mr Cassell and Edwards to have your non-prosecution agreement voided you would be able to testify as a witness in this matter correct MR CASSELL Form and foundation Calls for a legal conclusion THE WITNESS Fifth BY MR PAGLIUCA Absent the efforts by Mr Cassell and Mr Edwards to void your non-prosecution agreement you would be willing to testify as a witness in this Page Epstein Confidential case correct MR CASSELL Form and foundation Speculation THE WITNESS Fifth BY MR PAGLIUCA And absent the efforts by Mr Cassell and Mr Edwards to void your non-prosecution agreement your willing truthful testimony in this case would be helpful to Ms Maxwell correct MR CASSELL Form Foundation Calls for a legal conclusion Speculation THE WITNESS Fifth BY MR PAGLIUCA You were asked some questions by Mr Cassell about the lawsuit by Ms Roberts against you Its true is it not that the allegations contained in that complaint against you by Ms then Roberts or Giuffre were false correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And any allegations in that complaint by Ms Giuffre/Roberts against you relating to Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Ms Maxwell were false correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Can you tell me Mr Epstein given that the allegations against you in the complaint by Ms Roberts/Giuffre were false why did you settle the lawsuit MR CASSELL Form Foundation MR GOLDBERGER And attorney-client privilege MR WEINBERG Attorney-client privilege Sorry Jack MR GOLDBERGER Thats okay Marty THE WITNESS Fifth BY MR PAGLIUCA And without regard so Im not asking you for any communication between you and any lawyer Given the fact that the allegations given by Miss Giuffre/Roberts against you were false without discussing any information communicated to you by any lawyer what were your personal reasons for settling the lawsuit MR CASSELL Form Foundation Page Epstein Confidential THE WITNESS Fifth MR WEINBERG And his and his state of mind is inseparable from attorney-client communications MR PAGLIUCA Right Im not asking for any attorney-client communications so we are clear BY MR PAGLIUCA I dont recall if I asked you or not but I will ask you now What were the terms of the settlement agreement between yourself and Ms Giuffre/Roberts A Fifth MR GOLDBERGER And the standing objection on confidentiality MR PAGLIUCA Understood BY MR PAGLIUCA Mr Epstein you read Ms Roberts Ms Virginia Roberts/Giuffres statements published in the media about Ghislaine Maxwell correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA When you read those statements you Page Epstein Confidential understood that the statements made about Ms Maxwell were false correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understood that those statements were false because Ms Maxwell did not recruit Virginia Roberts to have sex with you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understood that the statements were false because Ms Maxwell did not assist anyone including yourself in sexually trafficking Virginia Roberts to any person correct MR CASSELL Object to form and foundation And just so the record is clear if I just use the words form foundation MR PAGLIUCA That is fine with me MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understand that Virginia Roberts was Page Epstein Confidential not when she claims to have met you true MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understand that Virginia Roberts was not at the time that she claims to have met you correct MR CASSELL Form foundation THE WITNESS Fifth BY MR PAGLIUCA You understand well isnt it true that Ms Roberts represented to you at the time that she met you that she was years old MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Isnt it true that Ms Roberts represented to others in your presence that she was over the age of MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Isnt it true that Ms Roberts represented to Ms Maxwell that she was over the age of Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Mr Cassell asked you some questions about a purported hospital visit involving you and Ms Roberts/Giuffre in New York Do you recall that if you know that Ms Roberts represented to the hospital folks that she was over the age of MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Now when you met Ms Giuffre/Roberts in addition to telling you that she was over the age of she represented to you that she worked as a masseuse at Mar-a-Lago correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And you would have met her sometime in the late fall because Mar-a-Lago is closed at least the spa part of Mar-a-Lago is closed during the summer correct MR CASSELL Form Foundation Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA And in the spa would have been closed during the summer correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA It was your decision to hire Ms Giuffre as a masseuse understanding that she was over the age of correct MR CASSELL Form foundation THE WITNESS Fifth BY MR PAGLIUCA And she was not recruited by you or anyone else to have sex with you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Now at the time that Ms Giuffre met you and represented that she was a masseuse and over the age of she was driving her own car correct MR CASSELL Form foundation THE WITNESS Fifth Page Epstein Confidential BY MR PAGLIUCA At the time that Ms Giuffre/Roberts met you and told you that she was over the age of and a masseuse she was living with someone that she identified as her fiance correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA At the time that Ms Giuffre met you represented to you that she was a masseuse over the age of driving her own car and living with her fiance in an apartment she had the ability to come and go from your residence as she pleased correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You never forced Ms Roberts ever to stay over your house at night correct MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA Ms Roberts was never forced to do anything by you correct Page Epstein Confidential MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA Ms Roberts was not a sex slave correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And you never sexually trafficked Ms Roberts to anyone correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA At the time Ms Roberts made statements to the media about you and Ms Maxwell you told Ms Maxwell on January 25th that You have done nothing wrong and I would urge you to start acting like it Go outside head high not as an escaping convict Go to parties Deal with it Do you remem recall making that written statement to Ms Maxwell in an e-mail produced in this case on January 25th MR CASSELL Form Foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR PAGLIUCA And at the time that you made that e-mail statement to Ms Maxwell you made it because it was true correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA When you said to Ms Maxwell in your written communication on January 25th You have done nothing wrong you were referring to Ms Giuffre/Roberts false claims that somehow Ms Maxwell had participated in sexual misconduct with Ms Giuffre/Roberts correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA When you said to Ms Maxwell You have done nothing wrong you were telling her that you knew that she had not been involved in any illegal activity associated with you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You urged Ms Maxwell to start acting like Page Epstein Confidential she had done nothing wrong because you knew that she had in fact done nothing wrong correct MR CASSELL Form Foundation Calls for speculation THE WITNESS Fifth BY MR PAGLIUCA When you told Ms Maxwell Go outside head high not as an escaping convict you were encouraging her to act like she had done nothing wrong because in fact she had done nothing wrong correct MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA You were responding to an e-mail sent to you by Ms Maxwell on January 24th in which she indicated I would appreciate it if would come out and say that she was your girlfriend I think she was from end to Do you recall receiving that communication from Ms Maxwell and responding to it MR CASSELL Form Foundation THE WITNESS Fifth Page Epstein Confidential BY MR PAGLIUCA You responded Okay with me because in fact was your girlfriend from at least the end of through correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA It is true that neither you nor Ms Maxwell trained Virginia Roberts to have sex with anyone correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And it is true that you never pimped Virginia Roberts/Giuffre out to any other person correct MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA To your knowledge Virginia Roberts/Giuffre did not have sex with Alan Dershowitz MR CASSELL Form Foundation BY MR PAGLIUCA Page Epstein Confidential Correct A Fifth Any other world leaders correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Any other political figures in the United States MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Any other entertainers A Fifth MR CASSELL Form Foundation THE WITNESS Sorry BY MR PAGLIUCA In particular David Copperfield MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understood that Ms Roberts/Giuffre left the United States in roughly to go to Thailand correct A Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential And the last time that you spoke or saw her was prior to her leaving for Thailand correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You understood that Ms Roberts/Giuffre went to Thailand because she had a warrant out for her arrest for theft from the Roadhouse Grill correct MR CASSELL Form Foundation Calls for a legal conclusion THE WITNESS Fifth BY MR PAGLIUCA You were asked some questions by Mr Cassell regarding the I cant recall what he referred to it as I think it was the Palm Beach investigation Are you aware that in approximately March of Im just going to wait for that noise to die down here whatever that is Youre aware that in approximately March of the Palm Beach Police Department began an investigation concerning you based on a report from a woman named Erica Gonzalez Page Epstein Confidential MR CASSELL Form Foundation MR GOLDBERGER And attorney-client privilege THE WITNESS Fifth BY MR PAGLIUCA Im not asking you for any information based on attorney-client privilege Mr Epstein for any of these questions Im assuming that you were provided and read police reports related to the Palm Beach investigation Based on your reading of those reports and not based on any conversations with any lawyers that you may have had at the time you are aware that in approximately March of the Palm Beach Police Department began an investigation concerning you based on a report from a woman named Erica Gonzalez A Fifth You were provided with a copy of the police reports related to that investigation correct A Fifth MR GOLDBERGER And attorney-client privilege Page Epstein Confidential BY MR PAGLIUCA The police reports generally indicated that allegations that you had sexual contact with females under the age of in the Palm Beach area correct A Fifth Virginia Roberts/Giuffre was not one of the alleged victims discussed or contacted in connection with that investigation correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And to your knowledge Virginia Roberts/Giuffre was never contacted by the Palm Beach Police Department MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA None of the alleged victims in the Palm Beach investigation identified Ghislaine Maxwell as a part of any alleged sexual contact scheme correct MR CASSELL Form Foundation THE WITNESS Fifth Page Epstein Confidential BY MR PAGLIUCA Youre aware that no one connected with that investigation accused Ms Maxwell of any wrongdoing MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA None of the alleged victims in the Palm Beach investigation claimed that they traveled with you in any airplane correct A Fifth None of the alleged victims in the Palm Beach investigation claimed that they traveled with you outside of the State of Florida correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA None of the alleged victims in the Palm Beach investigation claimed that you have been introduced to them by Ghislaine Maxwell correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA In fact the majority of the alleged Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential victims in the Palm Beach investigation claimed to have been recruited by someone named Haley Robson correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Youre aware Mr Epstein that these police reports are available as a public record by request to the Palm Beach Police Department A Fifth And youre aware Mr Epstein that unredacted versions of these police reports can be obtained from the States Attorneys Office hereby a letter request correct MR CASSELL Form form Foundation THE WITNESS Fifth BY MR PAGLIUCA Mr Cassell asked you some questions earlier about some police reports related to Ms Roberts/Giuffre related to her claims that she had been sexually assaulted here in Florida by men other than you Do you recall those questions A Yes Page Epstein Confidential Okay Are you aware that those police reports are also available by simply requesting them from the Palm Beach Police Department MR CASSELL Form Foundation Calls for a legal conclusion THE WITNESS Fifth MR CASSELL Can we hold on one second MR PAGLIUCA Sure Having a problem there MR CASSELL Take seconds to see if we can get these going All right Youre on Jeff MR PAGLIUCA Okay BY MR PAGLIUCA With regard to the Palm Beach Police Department investigation youre aware that none of the alleged victims in that matter claimed to have lived with you MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Youre aware that none of the alleged victims in that matter claimed to have stayed with Page Epstein Confidential you overnight in any residence MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Youre aware that none of those alleged victims claimed to have ever met or talked to Ms Maxwell MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And youre aware that none of those alleged victims ever claimed to have been paid by Ms Maxwell MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA It is true Mr Epstein that you at least during timeframe that we are talking about here so I will say from lets say through enjoyed getting a massage is that correct A Fifth And you had many masseuses that you hired to come to your house to give you a massage correct MR CASSELL Object to form Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA Many of those masseuses were contacted as part of the Palm Beach Police Department investigation do you recall that A Fifth And many of those masseuses that were contacted indicated that all of their massages were professional and paid for by you do you recall that MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Now you after Ms Roberts left the country as a result of the warrant out for her arrest for theft you later learned that she was bringing civil claims against you purporting that you had sexually assaulted her correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And those claims were raised up by her after a lot of publicity had occurred related to the Palm Beach investigation about you with the allegations of sexual misconduct correct Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA There were widespread media reports detailing the allegations about you in the press here in the South Florida area at the time correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Would you agree with me Mr Epstein that the police the leaking of the police reports and the leaking of the information to the press the reporting of the allegations by the press made you an easy target for anyone who wanted to make a claim of sexual misconduct against you MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And indeed there were many people who began falsely claiming that you had engaged in some form of sexual misconduct with them MR CASSELL Form Foundation THE WITNESS Fifth Page Epstein Confidential BY MR PAGLIUCA You were also an easy target for unscrupulous lawyers to make those claims and promote those claims against you correct MR CASSELL Form Foundation Vague THE WITNESS Fifth BY MR PAGLIUCA For example there was a lawyer now disbarred and in prison named Mr Rothstein who was promoting lawsuits against you as part of a Ponzi scheme here correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And Mr Rothstein was trying to convince people to buy shares in litigation against you and the outcome of litigation against you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Mr Rothstein worked with an individual named Bradley Edwards prior to Mr Rothstein being prosecuted and imprisoned correct Page Epstein Confidential MR CASSELL Form Foundation Lack of personal knowledge THE WITNESS Fifth BY MR PAGLIUCA And you knew personally that Mr Rothstein worked with Mr Edwards because you sued both Mr Rothstein and Mr Edwards in case captioned Jeffrey Epstein Plaintiff versus Scott Rothstein individually Bradley Edwards individually and L.M individually in correct MR CASSELL Form Foundation Lack of personal knowledge THE WITNESS Fifth BY MR PAGLIUCA That would be in So let me amend that The question would be in MR CASSELL Form Foundation Lack of personal knowledge BY MR PAGLIUCA Your lawyer at the time was somebody named Robert Critton correct MR CASSELL Form foundation Lack of proper pronunciation Its Critton I think Page Epstein Confidential BY MR PAGLIUCA Critton Okay C-R-I-T-T-O-N A Fifth You say Critton I say Critton I dont know how to MR CASSELL Jack might know MR GOLDBERGER I hate to weigh in on it but Mr Cassells Professor Cassell is correct BY MR PAGLIUCA In that lawsuit you claimed that Mr Rothstein and Mr Edwards manufactured claims against you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA In that lawsuit you alleged that Mr Rothstein and Mr Edwards were guilty of criminal conduct including running a Ponzi scheme securities fraud perjury and other crimes correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You indicated well isnt it true that Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Mr Rothstein and Mr Edwards were able to have women change their stories about you and make false allegations against you for money MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA In this case you are aware that Mr Edwards represents Ms Giuffre/Roberts A Fifth And you are aware that Mr Edwards and a lawyer named Jack Scarola contacted Ms Giuffre prior to the filing of any of this lawsuit to discuss with her allegations against you and Ms Maxwell correct A Fifth Is it it is true that Mr Edwards provided Ms Giuffre/Roberts with substantial information from both the Palm Beach investigation about you and other information that they had obtained so that they could promote their allegations against you in this litigation correct MR CASSELL Form Foundation Calls for speculation Lack of personal knowledge Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA It is true Mr Epstein that you did not sexually traffic Ms Roberts/Giuffre correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And its true Mr Epstein that Ms Maxwell did nothing to assist you in sexually trafficking Ms Giuffre/Roberts correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA The reason you are asserting a Fifth Amendment privilege here today has nothing do with Ghislaine Maxwell correct MR CASSELL Form Foundation Calls for speculation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR PAGLIUCA The reason you are asserting the Fifth Amendment privilege here today is to protect yourself Page Epstein Confidential from possible prosecution from others correct MR CASSELL Form Foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client MR WEINBERG Attorney-client privilege MR GOLDBERGER Yeah We got it Thanks MR WEINBERG Sorry Jack MR GOLDBERGER Thats all right BY MR PAGLIUCA It is true Mr Epstein you have no loyalty to Ms Maxwell as you sit here today correct MR CASSELL Form Foundation THE WITNESS Fifth MR PAGLIUCA I think I am done So if youll give me a minute Ill go over my notes We can take a five-minute break VIDEO TECHNICIAN Off the record at A recess was taken VIDEO TECHNICIAN On the record at Page Epstein Confidential BY MR PAGLIUCA I just have a few more questions Mr Epstein This person that youve identified as being your girlfriend this was roughly from the end of that was your girlfriend correct A Fifth Whats last name A Fifth And is it true that you had not MR CASSELL Im sorry Can we go the question before the last name I should have objected to form and foundation on that one MR PAGLIUCA What was last name MR CASSELL The one that was in fact your girlfriend Im sorry I apologize I should have form and foundation on that one MR PAGLIUCA Ill give it to you MR CASSELL Thanks MR PAGLIUCA In face here Ill ask it again so you can object Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR CASSELL Thank you BY MR PAGLIUCA It is true that was your girlfriend from approximately the end of correct MR CASSELL Form and foundation Thank you THE WITNESS Fifth BY MR PAGLIUCA Ms Maxwell had not been your girlfriend for some time prior to correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA In fact beginning prior to you spent less and less time with Ms Maxwell correct MR CASSELL Form Foundation And and chronology Are you saying are you going backwards in time MR PAGLIUCA Yes I am MR CASSELL Okay Vague THE WITNESS Fifth BY MR PAGLIUCA After when was your Page Epstein Confidential girlfriend Ms Maxwell spent less and less time in your presence correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA After when was your girlfriend Ms Maxwell spent less time at any of your residences correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA After Ms Maxwell increasingly decreased her visits to the your Palm Beach residence correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA After Ms Maxwell decreased the frequency of her travels with you correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And over time from moving forward Miss Maxwell spent less and less time with you Page Epstein Confidential correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And after moving forward Ms Maxwell spent less and less time so increasingly less time visiting your house in Palm Beach correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA You were the person responsible for hiring or firing any of your domestic employees from moving forward in time correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA From moving forward in time you made all of the decisions with regard to the hiring and firing of any employee correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA From moving forward you made all the decisions with regard to the job functions of any of Page Epstein Confidential your domestic employees correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Is it true that you had a falling out with Virginia Roberts/Giuffre because she was increasingly using drugs and abusing drugs from through MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA And you had a falling out with Ms Giuffre as a result of what you observed to be erratic behavior including criminal activity MR CASSELL Form Foundation Lack of personal knowledge THE WITNESS Fifth BY MR PAGLIUCA Do you ever recall meeting anyone named Renaldo Rizzo MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Ms Rizzo Mr Rizzo has claimed that he Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential was at a birthday party at your Palm Beach residence outside by your pool in which the only other attendees were children Is that a true statement or not MR CASSELL Foundation Misstates the record THE WITNESS Fifth BY MR PAGLIUCA It is in fact not true that you had any birthday party with minor children in attendance at your pool in Palm Beach correct MR CASSELL Foundation THE WITNESS Fifth BY MR PAGLIUCA Mr Rizzo has also made some claims that you had a number of younger-aged females in a limousine and you went to the Dubin residence in outside of New York City Is Mr Rizzos statement about that false A Fifth And it is true that Mr Rizzo has made up that story about you and the Dubins in an attempt to get money correct MR CASSELL Form Foundation Page Epstein Confidential THE WITNESS Fifth BY MR PAGLIUCA Mr Cassell asked you some questions about some someone from Sweden who Mr Rizzo claimed that you somehow lured into the United States for purposes of sexual trafficking That story by Mr Rizzo is also false correct MR CASSELL Form Foundation THE WITNESS Fifth BY MR PAGLIUCA Do you believe that Eva Dubin a medical doctor would participate in some scheme to sexually traffic anyone MR CASSELL Form Foundation Calls for speculation Lack of personal knowledge THE WITNESS Fifth MR PAGLIUCA Thats all the questions I have MR CASSELL I may want to consult with Ms McCawley at some point but maybe it will make sense for me to try and kind of see Page Epstein Confidential MS MCCAWLEY Thats fine MR CASSELL and shell backstop me in case I miss a trick along the way so REDIRECT EXAMINATION BY MR CASSELL We have the advantage by a very skilled court reporter whos given us a essentially a real-time transcript here But I noticed that on this real-time transcript at page line the question was asked to you by Mr Pagliuca Any relationship you had whether personal or business ended with Ms Maxwell more than years ago correct Do you recall being asked that question A Fifth MR GOLDBERGER Well I think you can answer that you recall being asked this question just MR CASSELL Thats all Im asking Im not trying to trip him up here BY MR CASSELL Let me just restate that again Do you recall being asked the following question Any relationship you had whether Page Epstein Confidential personal or business ended with Ms Maxwell more than years ago correct A Whats the question Im sorry Do I remember the question Any relationship you had A No Are you asking me do I remember Do you remember being asked that particular question A Sitting here at the moment I dont Okay I want to represent to you that you were asked the question Any relationship you had whether personal or business ended with Ms Maxwell more than years ago correct A I took the Fifth to that question if youre re-asking the question MR GOLDBERGER No I think hes just representing that that question was asked Dont and we can establish for purposes of the record that question was asked THE WITNESS Okay MR GOLDBERGER Okay BY MR CASSELL In fact you had a number of continuing personal interactions with Ms Maxwell within the Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential last years MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL I want to talk to you about some of the personal and other relationships you had with Ms Maxwell For example sir isnt it true that on December 11th you Ms Maxwell Ms Taylor and Virginia Roberts flew from the West Palm Beach Airport to the Teterboro New Jersey Airport MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And isnt it true that on December 14th you and Ms Maxwell and Miss Roberts flew from the Teterboro to the U.S Virgin Islands on your private jet MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Isnt it true sir that on January 26th you Ms Maxwell Ms Taylor and Ms Roberts flew from Teterboro to West Palm Beach MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that on March 9th you Ms Maxwell Ms Taylor and Virginia flew from Tangier Morocco to London England on your private jet MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And that was the trip where you Ms Maxwell and Ms Roberts met Prince Andrew the Duke of York right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Previously you were asked by Ms Pag Page Epstein Confidential Im sorry Mr Pagliuca whether there was any basis in fact for some of the questions I was asking you Would it be fair to say that one of the bases in fact for asking you questions about Virginias interactions with Prince Andrew would be a photograph depicting Ms Roberts and Prince Andrew MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You were asked some questions about a lawsuit that was styled Edwards versus Im sorry Epstein versus Rothstein et al When I ask you a question about the piece of that case that would be described as your claim against Brad Edwards Do you understand the setup for the question A Yes You voluntarily dismissed your legal claims against Brad Edwards right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client Page Epstein Confidential privilege BY MR CASSELL To your knowledge there is no lawsuit pending today by you against Mr Edwards right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client BY MR CASSELL When you traveled to England with Virginia and Ms Maxwell Ms Maxwell held Virginias passport right MR PAGLIUCA Object to form and foundation It has been asked and answered as well I didnt go into this and so Im not sure why were going over it again THE WITNESS Fifth BY MR CASSELL You had a relationship with Ms Maxwell when you traveled to with her to England right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL Mr Pagliuca was suggesting there was no basis in fact for some of the questions that I asked One of the bases in fact would have been Ms Maxwells possession of a passport reflecting Virginias age to be at the time she flew into England with you MR PAGLIUCA Object to form and foundation THE WITNESS Can you ask the question BY MR CASSELL Isnt that true MR PAGLIUCA Same objection THE WITNESS Fifth BY MR CASSELL You were asked questions about an e-mail in which you used the phrase Hold your head high Do you recall just being asked just being asked those questions A Yes I want to talk about the phrase now I want to go into the substantive issues With regard to the phrase Hold your head high the reason you used that phrase is you didnt Page Epstein Confidential think there was anything wrong with having sex with underage girls do you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact you have used words along the lines of having sex with a minor girl is like stealing a bagel true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And that in fact is your view today about the status of having an adult man decades older than an underage girl having sex with that underage girl right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What is your view of men who are decades older having sex with 16-year-old girls MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL What is your view of men who are decades older having sex with 17-year-old girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You believe that a man can hold his head high after having sex with a 16-year-old girl even if hes decades older than that girl true MR PAGLIUCA Object to form and foundation and foundation THE WITNESS Fifth BY MR CASSELL You were asked various questions by Mr Pagliuca MR CASSELL Am I pronouncing that MR PAGLIUCA No MR CASSELL Im sorry MR PAGLIUCA The is silent Think lasagna MR CASSELL Okay Page Epstein Confidential MR PAGLIUCA Pal Hes your pal BY MR CASSELL You were asked some questions by Mr Pagliuca got it okay by Mr Pagliuca about whether this litigation would affect you You just recall being asked those questions A Yes With regard to those questions its true sir that this litigation will affect your reputation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe all the ways in which you foresee this litigation affecting your reputation MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL This litigation will affect the reputation of associates of yours wont it MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL This litigation has the potential to affect the reputation of Bill Clinton right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL This litigation has the potential to affect the reputation of Prince Andrew right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL This litigation has the potential to affect the reputation of Alan Dershowitz right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You could have been a Defendant in this action right Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact as a pragmatic matter you are essentially a Defendant in this action right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You realize that many of the allegations in this litigation involve your interactions with Maxwell working together against Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You understand that if you turned over all the e-mails that we requested of you that would provide a basis for you us let me rephrase that You understand that if you turned over all the documents weve requested in the subpoena that that would provide basis for a defamation action by Page Epstein Confidential Ms Giuffre against you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You understand that if you turned over all the documents that we have requested in this case that would provide a basis for joining you into this case as a co-Defendant of Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What do all the documents that we have requested of you show with regard to your involvement in Ms Maxwells statements against Virginia MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL All the documents that weve requested from you would show that you have coordinated closely with Ms Maxwell to attack and defame Virginia right MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell continues to provide emotional support for you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Because of the sexual abuse youve committed against girls you lack very many friends at this point in time true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Name anyone whos well strike that Maxwell has been in a business relationship with you recently right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You and Maxwell need to continue to be in Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential touch with each other because of interactions that youve had of a business nature right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the ways in which you and Maxwells affairs are intertwined currently MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Please describe the way yours and Maxwells business affairs are intertwined currently MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You were asked and this is kind of a setup question again You were asked some questions about a lawsuit filed by Jane Doe and Jane Doe against the United States seeking to enforce rights under the Crime Victim Rights Act Do you recall those general Page Epstein Confidential questions A Yes I want you to assume for a moment that that lawsuit is dismissed tomorrow If the lawsuit were to be dismissed tomorrow and I were to ask you all of the same questions the day after tomorrow you would give the same answers wouldnt you MR PAGLIUCA Object to form and foundation MR GOLDBERGER Why dont you do that and well find out THE WITNESS Fifth BY MR CASSELL That case isnt going to be thrown out though because its meritorious right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL In fact you conspired with the U.S Attorneys Office to conceal the existence of your Page Epstein Confidential non-prosecution agreement until it was concluded right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The non-prosecution agreement binds the U.S Attorneys Office for the Southern District of Florida correct MR PAGLIUCA Object to form and foundation BY MR CASSELL Im sorry Let me rephrase that The non-prosecution agreement binds only the U.S Attorneys Office for the Southern District of Florida correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL Your non-prosecution agreement does not cover sex offenses in you have committed in the Page Epstein Confidential State of New York does it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL The non-prosecution agreement does not cover sex crimes committed in for example the U.S Virgin Islands or New Mexico does it MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL You would still be unavailable to testify in the sense that you would have invoked your Fifth Amendment even without that lawsuit right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL Which prosecution Im sorry Which jurisdictions are you fearful might Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential prosecute you for sex offenses MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL You are fearful of organizations Im sorry You are fearful of prosecuting entities outside the Southern District of Florida prosecuting you for sex offenses correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL You are fearful of law enforcement organizations outside the United States prosecuting you for foreign sex offenses correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client Page Epstein Confidential BY MR CASSELL Part of the basis for you asserting your Fifth Amendment privilege today was that you are fearful of incriminating yourself in foreign criminal prosecutions correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL In fact you lack any basis for asserting the Fifth Amendment privilege with respect to foreign criminal prosecutions right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client BY MR CASSELL Please tell me everything you know about your girlfriend A Fifth In fact during the period to Maxwell was your girlfriend not MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Between and you had threesomes right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And when you had threesomes one of the participants in the threesome was your girlfriend true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The threesomes you had almost invariably involved Ghislaine Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And when I say they almost invariably involved Ghislaine Maxwell sometimes you were in Page Epstein Confidential threesomes with other young girls that were not your girlfriend or not MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When I look at the flights that Virginia Roberts was on between March 8th and March no lets see What do I have No Im sorry Strike that If I look at the flights that Virginia Roberts is on according to Dave Rogers flight logs between December 11th and August 21st on initial review I do not see a single entry reflecting a on those flights Is that a correct understanding of those the passengers on those flights MR PAGLIUCA Object to form and foundation Speculation THE WITNESS Fifth BY MR CASSELL Is there some reason is not found frequently or even at all in the flight logs during this period of time Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Isnt it true that the reason is not found on these flight logs is she was not your girlfriend during that period of time MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And isnt the reason that Ghislaine Maxwell is found I believe invariably or certainly almost invariably on these flights I guess I should say almost invariably on these flights is that she was your girlfriend at the time MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In early you were having threesomes with Ms Maxwell right MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL I believe we already marked as an exhibit MS MCCAWLEY July MR CASSELL Oh this is the July Maybe we should mark this as an exhibit Let me mark this as a new exhibit I think this is JE14 MS MCCAWLEY I think this is going to be MR CASSELL Okay Strike that This will become JE11 which I represent is a transcript of Ms Maxwell taken on July 22nd You can take a look Im sorry I dont have an extra one Plaintiffs Exhibit JE11 Transcript of Ms Maxwell taken on July was marked for identification BY MR CASSELL Im looking at page If we look at page Im sorry If we start at page we see Did you engage in sexual activities with anyone other than Mr Epstein at Mr Epsteins home in Palm Beach Page Epstein Confidential Do you see that question Im just asking you whether you see that question A Yes sir After the inevitable form and foundation question Mr Pagliuca we see an answer I did Do you see that there A Yes And if we continue on down we see Was there more than one person with whom you engaged in sexual activities other than Mr Epstein at Mr Epsteins home The answer is Yes Do you see that there as well A Yes And you see the questions here I dont actually have a name Thats testimony by Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Yes BY MR CASSELL This is so Ms Maxwell indicates that she knew the name of the person at that time You see that on lines and on page MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Im sorry Can you repeat the question BY MR CASSELL Yeah Lines and theres a question Did you know the name at that time And then line At that time I did A I see Do you see that that question there A Yes This is a long way of saying that Ms Maxwell is indicating that sometime in the late and early she was having threesomes with you herself and another person A Is that what it says Im sorry MS MCCAWLEY Line BY MR CASSELL Line through Maybe I should ask it if Ms Maxwell testified that she had threesomes who would the threesomes have been with MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL She had threesomes with you and another women correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And the other woman was not was she MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Who was the other woman in the threesomes that you had in this period of time with Ms Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The only reason Ms Maxwell consented to have threesomes with you was that she was your girlfriend at the time right MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL She was in fact your girlfriend from the late Im sorry from around to around right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact she actually continued to be your girlfriend into into MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When did you stop considering Ms Maxwell to be your girlfriend MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Mr Pagliuca asked you some questions about Haley Robson Do you recall those questions A Yes Page Epstein Confidential Haley Robson reported to Ghislaine Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ghislaine Maxwell controlled Haley Robson right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ghislaine Maxwell used Haley Robson to help bring girls to you for sex right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL What was Haley Robsons role in your household affairs MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Mr Pagliuca asked you some questions about whether you are an easy target for lawsuits Do you recall those questions A Yes One of the reasons you were an easy target for lawsuits sir was that you sexually abused dozens and dozens of underage girls right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL One of the reasons you were an easy target for Virginia Roberts for sexual assault is because you had in fact committed sexual assault against Virginia Roberts MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You settled dozens of lawsuits filed against you by underage girls in and didnt you MR PAGLIUCA Object to form and Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL The reason you settled those lawsuits is that you had sexually abused the girls who filed lawsuits you against you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Every one of the girls who filed a lawsuit against you had been sexually abused by you right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Is there a single girl who has filed a lawsuit against you that lacked merit MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL When Virginia Roberts then known as Jane Doe filed a lawsuit against you everything Page Epstein Confidential in her lawsuit Im sorry everything in her complaint against you was true right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If I were to give you an unconditional waiver of the confidentiality form for the lawsuit that Virginia filed against you for the settlement that Virginia had of the lawsuit she filed against you you would refuse to sign that today right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL Would you sign an unconditional waiver of confidentiality with regard to the settlement of that lawsuit MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client Page Epstein Confidential privilege BY MR CASSELL As you sit here today you continue to maintain loyalty to Ghislaine Maxwell today right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You were asserting the Fifth Amendment privilege today not only to protect yourself but also to protect Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If you had answered all my questions today it would have become clear that you were involved with Ms Maxwell in sex trafficking of underage girls over a multiyear period right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If you had answered all my questions today Page Epstein Confidential it would have become clear that Ms Roberts has been telling the truth about Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Mr Pagliuca asked about whether you had terminated relationships with Ms Maxwell more than years ago You would agree with me sir that the time period time period of would be inside the last years mathematically MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You would agree that is less than years ago as we sit here today right A Yes MR PAGLIUCA Object to form and foundation BY MR CASSELL In Maxwell had access to certain of your bank accounts right Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA Object to form Foundation You already asked these questions by the way THE WITNESS Fifth BY MR CASSELL In Maxwell had control on certain of your bank accounts true MR PAGLIUCA Object to form and foundation Again you already asked these questions THE WITNESS Fifth BY MR CASSELL Previously I never had an opportunity to ask about who was the signatory on your accounts in So Id like to go over the signatories on your accounts in Were there any bank accounts in which Maxwell was a signator in any of your bank accounts MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Please describe for me all the signators on your bank accounts in A Fifth I want to talk about the bank accounts that were used to take care of the day-to-day management of your Palm Beach mansion in Which bank was that account with A Fifth Who was a signatory on that particular account A Fifth If there are bank records that are produced in this case showing Ms Maxwell as a signator on that account would those bank records be accurate MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Its fair to say that Ms Maxwell was a signator on the bank account that was involved most heavily in the day-to-day operations of your West Palm Beach mansion true MR PAGLIUCA Object to form and Page Epstein Confidential foundation I have a question Ive not seen any such bank records So do you have them and have they been produced MR CASSELL Well deal with that concern later THE WITNESS Fifth BY MR CASSELL Was Eva Dubin ever your girlfriend A Fifth Please tell me everything you know about Eva Dubin A Fifth Have you ever had sex with Eva Dubin A Fifth You in fact have had sex with Eva Dubin right A Fifth You paid for Eva Dubin to attend medical school right A Fifth One of the reasons you paid for Eva Dubin to attend medical school was to keep her quiet about her knowledge of your sexual abuse of minors Page Epstein Confidential correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Why did you pay to send Eva Dubin to medical school MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Eva Dubin continues to be loyal to you today true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR CASSELL Im getting close to the end I think this might be a good time for me to confer with counsel for a few minutes VIDEO TECHNICIAN Off the record at A recess was taken VIDEO TECHNICIAN On the record at Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL I want to ask you some questions about a visit to a New York hospital MR CASSELL Oh great Thank you BY MR CASSELL You and Ms Maxwell took Virginia to a New York hospital when she was under the age of correct MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL And at the time Ms Roberts was in great pain true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Because of the pain Ms Roberts was in you and Ms Maxwell handled the admission with the hospital correct MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL And because you knew it would create complications if Ms Maxwell was a minor under the age of you and Ms Maxwell represented that Virginia was true MR PAGLIUCA Object to form and foundation THE WITNESS State your you want to repeat your question MR CASSELL Sure THE WITNESS I think you said Miss Maxwell was under the age of MR CASSELL Let me strike the last question and re-ask it Thank you BY MR CASSELL Because you knew it would create complications if Ms Roberts was a minor under the age of you and Ms Maxwell represented that Miss Roberts was years old true A Fifth MR PAGLIUCA Object to form and foundation BY MR CASSELL How old did you tell the New York City Page Epstein Confidential hospital that Virginia Roberts was MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Im going to ask you some questions about David Copperfield You know David Copperfield right A Fifth David Copperfield has been in your presence has been in your presence strike that David Copperfield and you have been together in the presence of minor girls under the age of right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Have you ever provided girls under the age of to David Copperfield for sexual purposes MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Page Epstein Confidential BY MR CASSELL Based on everything I know in this case it would seem logical that you provided girls under the age of to David Copperfield for sexual purposes Am I missing something if I reach that conclusion MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL With regard to the Palm Beach Police Department investigation the Palm Beach Police Department identified many persons under the control of Ms Maxwell who had paid girls for underage sex MR PAGLIUCA Object to form and foundation BY MR CASSELL True A Theres no question True MR PAGLIUCA Same objection THE WITNESS Fifth BY MR CASSELL With regard to the girls that the Palm Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential Beach Police Department investigated how were the payments made to those girls MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Miss Maxwell was aware of all the payments that were going to the girls in the Palm Beach Police investigation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL In fact Miss Maxwell had control of payments that were made to the girls in the Palm Beach Police Department investigation MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell is one of your closest friends true MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth BY MR CASSELL How close is your relationship with Ms Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Can you name anyone whos a closer friend than yours over the last ten years than Miss Maxwell MR PAGLIUCA Object to the form and foundation THE WITNESS Fifth BY MR CASSELL You cant name anyone whos been a closer friend of yours over the last ten years than Ms Maxwell right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL The person that you have had the most sexual activity with over the last years is Ms Maxwell true Page Epstein Confidential MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Is there anyone over the last years that youve had more sexual activity with than Ms Maxwell MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell is the longest let me see Strike that You havent had an intimate relationship with anyone for a longer period of time than Ms Maxwell over the last two decades have you MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Through legal counsel and other means you have been coordinating with Ms Maxwell with regard to this litigation right MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL You purchased a town home in New York for Miss Maxwell for millions of dollars true MR PAGLIUCA Object to form and foundation Youve already asked this question Its already been answered THE WITNESS Fifth BY MR CASSELL How are you coordinating with Ms Maxwell on this litigation MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Youre hoping Ms Maxwell prevails in this litigation true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential BY MR CASSELL What is your arrangement with Ms Maxwell with regard to paying any settle any judgment that might be reached against her in this case MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Ms Maxwell has had discussions with you about whether you would pay a judgment in this action against her right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Your interests in Ms Maxwell are compatible in this case true MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL Both you and Ms Maxwell are hoping that the case would be dismissed true MR PAGLIUCA Object to form and Page Epstein Confidential foundation THE WITNESS Fifth BY MR CASSELL Previously you sent e-mails to Ms Maxwell indicating your desire to have the publicity in this case die down right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If the case were to settle that would help the publicity in this case die down right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL If this case were to resolve that would be useful for your purposes and Maxwells purposes right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have also been coordinating with Page Epstein Confidential Alan Dershowitz with regard to this litigation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER And attorney-client privilege BY MR CASSELL You are in a joint defense arrangement with Alan Dershowitz at this time MR PAGLIUCA Object to form and foundation THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege Im sorry Attorney-client privilege and to the extent there is a confidentiality agreement in place or or a joint defense agreement I would object on that basis BY MR CASSELL You have a common interest agreement with Alan Dershowitz right MR PAGLIUCA Object to form and foundation Page Epstein Confidential THE WITNESS Fifth MR GOLDBERGER Attorney-client privilege BY MR CASSELL You have a common interest with Alan Dershowitz in this litigation right MR PAGLIUCA Object to form and foundation THE WITNESS Fifth BY MR CASSELL You have a common interest with Ghislaine Maxwell in this litigation right MR PAGLIUCA Asked and answered this question Im going to object to form and foundation THE WITNESS Fifth MR CASSELL I have no further questions MR PAGLIUCA I have no additional questions MR GOLDBERGER Excellent MR CASSELL Thank you VIDEO TECHNICIAN The time is This concludes the deposition Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential MR PAGLIUCA I do want a transcript THE COURT REPORTER Do you have a standing order MR PAGLIUCA Yeah They should have whatever we want I think its E-Tran THE COURT REPORTER A rough transcript MR PAGLIUCA I dont need a rough I dont think Signature was not waived The deposition concluded at p.m Page CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH I the undersigned authority certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn on September WITNESS my hand and official seal this 13th day of September DARLINE MARIE WEST Notary Public My Commission Expires October FF Page REPORTERS CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I DARLINE MARIE WEST RPR certify that I was authorized to and did stenographically report the foregoing deposition and that the transcript is a true record thereof I further certify that I am not a relative employee attorney or counsel of any of the parties nor am I a relative or employee of any of the parties attorney or counsel connected with the action nor am I financially interested in the action Dated this 13th day of September DARLINE MARIE WEST RPR Page I I A STATE OF FLORIDA COUNTY OF PALM BEACH I JEFFREY EPSTEIN hereby certify that I have read the foregoing transcript of my deposition and that the statements contained therein together with any additions or corrections made on the attached Errata Sheet are true and correct Dated this day of JEFFREY EPSTEIN The foregoing certificate was subscribed to before me this day of by the witness who has produced a as identification and who did not take an additional oath Notary Public my commission expires Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SERV I CES Case Document Filed 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