Giuffre_Maxwell_Batch4_p00559.png

Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 7 of 10 He had no personal knowledge whether anything other than massage occurred with the females that went over to Mr. Epstein’s home: Q. Well, you said you observed bringing a girl over. A. No. I'm just saying -- like, I brought them over, yes. But I have never observed anything, like, sexual. Never anything -- like to where it would be an illegal activity. Like, any time I was there, everybody was dressed. They were all talking like it was just, like, people hanging out in a room, you know what I mean? There was never anything going on when I was there, so... Q Do you have any personal knowledge as to whether anything other than a massage took place between Jeffrey and these girls? ANo. Q You did not see anything? A Nope. Q They didn't tell you afterwards anything happened? A Nope. (Tr. at 116). He testified that all of the females he brought over were his age, or at most a year younger, and he was 20. (Tr. at 234) Further, he never saw any sexual activity occur between Plaintiff and Mr. Epstein: Q Ms. Roberts described sexual acts that she participated in with Jeffrey; correct? A Yes. Q And you did not observe that? ANo. (Tr. at 121). 8. “Defendant and/or Her Joint Defense Partners Previously Fed [Plaintiff's False Claims of Sexual Assault] to the Media” (Reply at 9). Ms. Maxwell, and her “joint defense partners,” have never “fed” to the media anything about Plaintiffs various false claims of sexual abuse. To the contrary, all of the email exchanges between Ms. Maxwell, Mr. Gow, Mr. Epstein and others indicate Ms. Maxwell’s extreme reluctance to be involved with the media. The email quoted by Plaintiff in her Reply at page 5 simply shows that Mr. Gow picked up on the media’s 6