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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 7 of 17
be safe under Epstein’s roof, not least because he phoned her to reassure her, and she
also knew he had Ghislaine Maxwell with him at all times. When the girls’ mother
learned that Epstein had, regardless, allegedly molested her 16-year-old daughter, she’d
wanted to fight back.
“I Tried to Warn You about Sleazy Billionaire Jeffrey Epstein in 2003,” Vicky Ward, January 6,
2015, Daily Beast Article (Emphasis added). Defendant would not answer many questions
concerning her role with in the molestation of these girls while she was sharing a house with
Maria Farmer and Jeffrey Epstein:
Q. Do you know whether or not Maria Farmer was ever at Mr. Wexner’s property in
Ohio?
Mr. PAGLIUCA: Can you tell me how that relates to this order, counselor?
MR. BOIES: Yes, I think it goes directly to the sexual activity related to Maria Farmer
and what Mr. Epstein was doing with Maria Farmer. Again, you can instruct not to
answer.
MR. PAGLIUCA: I’m trying to understand why you are asking these questions before I -
MR. BOIES: I’m asking these questions because these are people who not only have
been publicly written about in terms of the sexual activity that they were put into in
connection with Mr. Epstein, but the person who wrote about them is someone who
talked to the witness about it, and I think that this is more than easily understood cross-
examination.
MR. PAGLIUCA: Your question was, do you know whether or not Maria Farmer was
ever at Mr. Wexner’s property in Ohio.
MR. BOIES: Yes. And if you let her answer, you will see where it leads. If you won’t let
her answer, the judge is going to determine it. And I just suggest to you that you stop
these speeches and stop debating, because you are not going to convince me not to
follow-up on these questions. If you can convince the court to truncate the deposition,
that’s your right, but all you’re doing is dragging this deposition out.
MR. PAGLIUCA: You have the opportunity to give me a good faith basis why you are
asking these questions.
MR. BOIES: [have given you a good faith basis.
MR. PAGLIUCA: You haven’t.
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Document Details
| Filename | Giuffre_Maxwell_Batch3_p00067.png |
| File Size | 339.6 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 2,155 characters |
| Indexed | 2026-02-04 12:38:48.751323 |