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ODr~wAnA OAR WNHeRF OCW WAIN OO PWN PB Page 74 say that? GHISLAINE MAXWELL: Well, I -- let me rephrase that. If there was fraud, I never saw it. What I saw or what I felt when I -- his -- I ran that office. I mean, ran. I didn't -- I was responsible for the staff. People worked. There were lawyers, there were accountants. I never heard him -- I never -- wit- -- I never felt anything, I don't know, icky. DAVID MARKUS: Did -- did you ever see him blackmail a -- GHISLAINE MAXWELL: Never. DAVID MARKUS: -- a client? GHISLAINE MAXWELL: No. DAVID MARKUS: Did you ever see him blackmail a -- an -- a friend or an acquaintance? GHISLAINE MAXWELL: Never. DAVID MARKUS: Okay. TODD BLANCHE: Well, so I think when folks talk about block -- blackmail, and we can talk about -- sorry about that. GHISLAINE MAXWELL: Sorry. TODD BLANCHE: We can talk about that now. There are a lot of allegations about him, which we'll -- which we should talk about and we can do that now. And the fact that he abused young women. on TIMA OB WN TE PRP rRPRP RB Ao BKB WHE OE ho ~] Page 75 GHISLAINE MAXWELL: Yes. TODD BLANCHE: Full stop. Okay. Which means, the way that I'm defining abuse, as has been widely reported, is that -- that he would cause young women in high school to be recruited to come to his house and give him massages. And a part of -- and the -- and the -- and as part of that, he would sexually abuse them, okay? GHISLAINE MAXWELL: Yes. TODD BLANCHE: So I want to talk about that. But as it relates to blackmail, the question is whether you're aware of any time, that any of the individuals we're talking about, and we'll talk about others, received massages from women who were under 18 or may have been under 18. And that whether there was any sexual assaults or sexual contact between any of these people and those masseuses, which would've allowed then, Mr. Epstein, potentially, to blackmail them and say, "You have to continue to work with me or you have to give me money, or else I'm going to tell the world that -- that -- that you did this." GHISLAINE MAXWELL: Right. I -- I think this is a really good place to start with how this story began. oO TN OA PWN EE RRR NFO wo Page 76 TODD BLANCHE: Okay. GHISLAINE MAXWELL: So even, let's assume that that premise is correct, that he was doing that and he was going to tell everybody, going to say, "oh, you know, you had inappropriate relations with an underage girl." If you don't have a video or photograph, photographic evidence, because I -- I'm not sure that even the FBI would take that. Well, maybe today, but certainly not back then, would take that seriously. So you have to have something to say, "Hey, you know, look, I've got this video of you doing terrible things and you need to." So I built those houses, many of them. I decorated those houses. I put the electricians in for the wiring. I never wired, nor saw, a single house that had any type of inappropriate, let's say, video surveillance. And I'll define that for you. Inappropriate surveillance would mean in a bathroom, in a bedroom, in any private area of a home. TODD BLANCHE: In a room where there were massages given? GHISLAINE MAXWELL: Inappropriate. I would say I would define "appropriate" surveillance to be the front door of a house, or potentially, as Page 77 in 71st Street, the physical plant. Anywhere else would be grotesque. TODD BLANCHE: So I just want to come back to -- I know I'm just hopefully stating the obvious, but when you say "the houses," you're talking about his New York -- GHISLAINE MAXWELL: Yes. TODD BLANCHE: -- brownstone? GHISLAINE MAXWELL: Yes. TODD BLANCHE: You're talking about the island in -- in the Caribbean? GHISLAINE MAXWELL: Yes. TODD BLANCHE: You're talking about the residence in Palm Beach? GHISLAINE MAXWELL: Yes. TODD BLANCHE: And you're talking about the ranch in New Mexico? GHISLAINE MAXWELL: Yes. TODD BLANCHE: Anywhere else? GHISLAINE MAXWELL: Paris. TODD BLANCHE: And in Paris. And so -- GHISLAINE MAXWELL: And the plane. I saw some ridiculous thing with the plane -- TODD BLANCHE: And the plane. Okay. GHISLAINE MAGNA®© LEGAL SERVICES MAXWELL: -- that was what we're 20 (Pages 74 to 77) DOJ-OGR-00022675