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Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 9 of 38 AIDUAWNHEHRFCOAIADAFOBWNHEHE Page 78 G Maxwell - Confidential over to the house in Palm Beach to give massages? A. It's important to understand that I wasn't with Jeffrey all the time. In fact, I was only in the house less than half the time, so I cannot testify to when I wasn't in the house how often she came when I wasn't there. What I can say is that I barely would remember her, if not for all of this rubbish, I probably wouldn't remember her at all, except she did come from time to time but I don't recollect her coming as often as she portrayed herself. Q. How many times a day on an average day would Jeffrey Epstein get a massage? MR. PAGLIUCA: Objection to the form and foundation. A. When I was at the house and when I was there with him, he received a massage, on average, about once a day. Q. Just once? A. Yes. Q. Were there days when he received SCUEMIDTUBAWNHEHOWCAIAAOAWNHE NMNNNNN Owe wn Page 80 G Maxwell - Confidential all, except for this story. Q. Do you recall Virginia Roberts calling you because she was having a medical crisis and you and Jeffrey taking her to the hospital? A. Ihave heard this absurd story and if any part of it were true I would remember that. I do not. Q. You don't remember taking her to the hospital? A. It's not that I don't remember it, it didn't happen. Q. How do you know it didn't happen? A. That's the sort of memory you would recall. Q. Do you recall, you said you don't remember her being at the New York mansion. When you were in New York would you stay at the New York mansion with Jeffrey? A. Istayed from time to time. Q. Do you recall Virginia being at the New York mansion when Prince Andrew came to visit? MR. PAGLIUCA: Objection to the Page 79 G Maxwell - Confidential four or five? MR. PAGLIUCA: Objection to the form and foundation. A. When I was present at the house, I never saw something like that. Q. Do you know if Virginia was required to be on call at all times to come to the house if Jeffrey wanted her there? MR. PAGLIUCA: Objection to the form and foundation. A. Ihave no idea of the arrangements that Virginia made with Jeffrey. Q. When Virginia was in New York, would Virginia sleep at Jeffrey's mansion in New York? MR. PAGLIUCA: Objection to the form and foundation. A. I don't recollect her being in New York and I have no idea where she slept. Q. You don't ever remember seeing Virginia Roberts in New York? MR. PAGLIUCA: Objection to the form and foundation. A. I would barely recollect her at MAGNA® DAIANDUBWNHRFPOWOWAAINDUOBWNH Page 81 G Maxwell - Confidential form and foundation. A. Like I told you, I don't recall her being at the house at all. Q. How many homes does Jeffrey have? MR. PAGLIUCA: Objection to the form and foundation. A. When I was working for him, I think he had six maybe. Q. Would Virginia stay with him in those homes? MR. PAGLIUCA: Objection to the form and foundation. A. Ican only testify for when I was present with him and I cannot say what she did when I wasn't present with him. Q. When you were present, would Virginia stay in the homes with him? A. I don't recall her staying in the houses. Q. Did you train Virginia on how to recruit other girls for massages? MR. PAGLIUCA: Objection to the form and foundation. A. No. 21 (Pages 78 to 81) LEGAL SERVICES