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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 10 of 27 WMBNAWAWNHY was at that time? A. No, I didn't know. Q. If I was to tell you she was born in December of '86 which would have made her 18 at the time, and you would say, not surprised? MS. EZELL: Objection, form. MR, WILLITS; Object to the form of the question. MR. HOROWITZ: Join. THE WITNESS: I would say I wouldn't know. BY MR, CRITTON: Q. Other than telling Louella did you say anything to anyone else when you saw i, the lady you believe was J naked in the sauna? A. I believe I mentioned that to my wife. Q. Allright. Anyone else? A. No, Q. And did continue -- assuming it was , did she continue to sleep in the sauna, that Is, she didn’t know you were there? A. She never knew that I was there. Q. She didn't at least acknowledge that she knew. Correct? A. Yes, correct. Page 352 Q. You were asked by Ms. Ezell -- I'm just going to cover a couple of things as long as I'm staying with Cathy here -- whether Louella, you had told us something about the picture of the Pope near a picture of a naked person, naked woman. That's what Louella told you, you never saw those photos, Correct? A. I did saw the pictures. Q. You did see the pictures? A. Yes. Q. And the photos that you saw of the naked woman that was near the Pope's photograph, was that someone that you knew or just a picture of a naked woman? A. It was somebody -- somebody that was a visitor in the house, but I don't know her name. Qo ANd the Visitors, tha one of the plane women, you described the women who came in on planes, or that they came with Mr. Epstein from time to time? A. They came with Mr. Epstein from time to time. Q. Allright. And those are women that I think you testified at your last deposition all appeared to be in their 20's or older, Is that OaOInn We WOANAH DWN 10 il 12 13 14 is 16 18 19 20 21 22 23 24 25 Page 353 correct? A. Lthink so, sir. Q. Allright. Iassume that in over the course of your life separate and apart from your wife you've seen a naked woman before. A. Yes, Q. And I assume that in your 50 some odd years -- how old are you, sir? A. 55. Q. Inyour 55 years you've seen pictures of naked women both photographs, paintings, statutes, Would that be a fair statement? A, Yes, Q. And in terms of at least in this particular case there is all sorts of -- as you know there is testimony, and you've been asked a number of questions about sex related issues, that is whether you saw in photographs or whether you saw anyone engaged in any type of sexual activity. Correct? A, Correct, Q. And I assume that you understand that men and women -- we'll start there first, that men and women actually do have sex in this world? A. Yes. Page 35¢ Q. That comes as no grand surprise to you? A. No, Q, And you understand that people actually enjoy sex from time to tme? A. Yes. Q. Are you familiar with that concept at least? A, Yes. Q. All right. And what may be typical sexual activity for one man and woman, or whatever the permutation might be, another couple, or another man and woman, or another man or woman may consider to be unusual or overly aggressive. MS. EZELL: Objection to form. BY MR. CRITTON: Q. True? cepe m Q. That's what I mean. Everyone has a different point of view about sex and what may be considered typical sexual activity for someone, someone else may consider that's a bit adventurous? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: ds orryour point of view 22 (Pages 351 to 354) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000336 GIUFFRE00 1026