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Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 30 of 179 Page 29 Q. Did you ever see Ghislaine Maxwell during that trip laying out by the pool? A. There was one time where we were all by the pool, yes. Q. Was Ghislaine Maxwell ever nude or topless by the pool? A. I don't recall. She was nude when she went swimming in the ocean. Q. At that moment in the USVI home, did you observe any photos there of nude females? A. I don't recall. Q. Besides Virginia, who you mentioned, you observed to be young, did you observe any other females that in your view appeared to be essentially under the age of 18? A. No. Q. Did you observe any females who you thought looked young, younger than you? A. No. Q. Do you remember an individual by the name of that you met during your time with Jeffrey Epstein? In Palm Beach? Yes. Yes. MAGNA® LEGAL SERVICES