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Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 13 of 38 DMIDHTBPWNHRFPDOANHA UY BWNHE Page 102 G Maxwell - Confidential A. I don't recall. Q. Did it change over the years or did the payment remain the same? A. I believe over the course of time it increased a little bit. Q. Was that the -- was that payment the payment that -- was the payment made with respect to the jobs, the work you were performing for Jeffrey, was that your sole income at that time? MR. PAGLIUCA: I object to the form. I'm also going to instruct you not to answer about sources of -- your personal sources of income outside of Mr. Epstein at all. MS. McCAWLEY: What's the basis for that? MR. PAGLIUCA: It's confidential, it's not part of this lawsuit. MS. McCAWLEY: We have a protective order and it is part of this lawsuit with respect to our damage claims. MR. PAGLIUCA: It's not and, in fact, you are not entitled to ask DIDO BWNFPWOOANDOAWNE NMNNNNNNDN OPBWNHRE OW Page 104 G Maxwell - Confidential worked for it and I had a loan, we did loans. Q. Soa loan through Jeffrey? A. I don't recall the exact transaction. Q. Did he purchase for you a helicopter during the time you were working for him? A. It was his helicopter. Q. When did you obtain your pilot license? A. I believe it was '98 or '99. Q. Was that for both airplanes and helicopters or just helicopters? A. Just helicopters. Q. Have you ever flown President Clinton on your helicopter? A. That is another one of Virginia's lies. Q. The question is have you ever done that? A. [have never flown President Clinton at any time ever, in any helicopter, in any place, any time, in any state, in any country, at any time anywhere. Page 103 G Maxwell - Confidential financial information of a defendant in this kind of case, in a defamation case unless and until there is a finding that you are entitled to punitive damages. That is clear in New York case law, both state and Federal. MS. McCAWLEY: We disagree on that point and we will come back to that. Q. From the source of payment from the source of Jeffrey, from your work, can you give me a range on that, do you know was it over $100,000? A. I just testified I don't recall. Q. You don't don't know if it was $500,000? A. It was less than that. Q. Somewhere between 100 and 500, would that be fair to say? A. Ibelieve it was between 100 and $200,000. Q. Did Jeffrey during the time that you were working for him purchase a town home for you? A. The subject of the townhouse is, I MAGNA® DAIANDUBWNHRFPOWODAIDUBWNHE Nh ow Page 105 G Maxwell - Confidential Q. Have you ever had dinner with President Clinton at Jeffrey's home, at any of Jeffrey's homes? A. No, I don't believe so. Q. Have you traveled on Jeffrey's planes with President Clinton? A. Yes, Ihave. Q. Would that have been in 2002? A. It's very hard for me to recollect exact dates but that sounds about right. Q. Was that during the time that Virginia was working for Jeffrey? A. I don't know that Virginia ever did work for Jeffrey. I don't exactly know if she testified to her so-called duties, we know she is a serial liar so I can't testify to what she did or didn't do. So I object to that characterization of her. So repeat the question, please. Q. Can you read the question back? (Record read.) Q. You can answer the question. A. What was the question again? Q. When you were traveling on the 27 (Pages 102 to 105) LEGAL SERVICES