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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 6 of 17
In the wake of this specific deposition testimony from Ms. Sjoberg, during her own
recent deposition, Defendant continued to refuse to testify about Ms. Sjoberg’s massages and
sexual activity with Epstein:
Q. Did Mr. Epstein pay Johanna for the massages that she gave Mr. Epstein?
Mr. Pagliuca: You just asked this question, and I told her not to answer. I will tell her not
to answer again for the same reasons.
Q. Do you know how much Mr. Epstein paid Johanna to give massages?
Mr. Pagliuca: Same instruction to the witness. Why do you believe this is within the
scope of the court’s order?
Mr. Boies: Because of the court’s reference to massages, and because I think how much a
girl who was hired to answer the phone was paid to give a “massage” goes to whether
there actually was or was not sexual activity involved.
Mr. Pagiluca: The witness has testified there wasn’t.
Mr. Boies: Perhaps it will surprise you, I think it should not, that I do not believe in my
deposition I need to simply accept her characterization without cross-examination. Now
that’s something the judge can decide, but a question as to how much this young girl was
being paid for a “massage,” I think goes directly to the issue of sexual activity.
See Schultz Decl. at Composite Exhibit 7, Excerpts from July 22, 2016 Deposition of Ghislaine
Maxwell at pg. 82:25-84:6.
Additionally, Defendant refused to answer questions concerning the sexual abuse
involving herself, Mr. Epstein, and Annie and Maria Farmer, described in a Vanity Fair article:
“What do you have on the girls?” [Epstein] would ask the question over and over again.
What I had “‘on the girls” were some remarkably brave first-person accounts. Three on-
the-record stories from a family: a mother and her daughters [Maria Farmer, Annie
Farmer, and their mother] who came from Phoenix. The oldest daughter, an artist whose
character was vouchsafed to me by several sources, including the artist Eric Fischl, had
told me, weeping as she sat in my living room, of how Epstein had attempted to seduce
both her and, separately, her younger sister, then only 16. He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted - and
would win. The girls’ mother told me by phone that she had thought her daughters would
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| Filename | Giuffre_Maxwell_Batch3_p00066.png |
| File Size | 373.4 KB |
| OCR Confidence | 95.4% |
| Has Readable Text | Yes |
| Text Length | 2,556 characters |
| Indexed | 2026-02-04 12:38:48.957043 |