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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 26 of 27 Page 415 Page 417 L I think you told us, you were asked 1 A. To bring the pictures from my computer? 2 questions about sex toys, I think you certainly 2 Q. Let me rephrase the question. I thought 3 described the back massagers, Correct? 3 what you said last time was that as to the 4 A. Yes. 4 pictures that you did see of naked women -- of a 5 Q. Ithink you said the only sex toys that 5 naked woman or naked women on the computer, that 6 you ever saw were in the armoire at the end of Mr. 6 you've looked at those photographs through your 7 Epstein's bed. 7 computer. 8 A. Yes. 8 A. No. 9 Q. Okay. And whatever other sex toys that 9 Q. Okay. Then I may have misunderstood you, 10 to which there was a reference, that's something 10 Was your reference to Ms. Maxwell's computer that 11 that Louella told you. Is that correct? 11 you made at the last deposition? 12 A. That's correct. 12 A. Yes. 13 Q. You were asked at the last deposition, I 13 Q. Okay. Your computer that you had either 14 don't remember who asked the question, but whether | 14 _ in the staff house or that you -- 15 you had ever seen pornography on any computer. I. | 15 A. Didn't access, 16 think one of your responses was you saw some 16 Q. You couldn't access those files? 17 photos of a naked woman who appeared to you to be | 17 A. That's correct. 18 a model. 18 Q. All right, now I'm with you. So the 19 A. Yes. 19 photographs you've talked of the nude individuals, 20 Q. Okay. Do you consider every photograph, 20 or the naked women, were the photographs that 21 we've already talked about with both, i.e., in 22 Ms. Maxwell's computer? 23 A. Yes. 24 Q. Thank you for clearing that up. I'm going to ask you to assume that C.W. 21 picture, painting of a naked nude woman to be 22 pornography? 23 MR. HOROWITZ: Form. 24 MS. EZELL: Objection, form. THE WITNESS: I consider -- well, if it's Page 416 who you've described as having come to Mr. Epstein's house on three or four times a week for a period of time, one of her claims in this case is that she has been emotionally traumatized by a frontal picture it's pornography, I will 1 2 3 4 5 her contact with Mr. Epstein. Just assume that to 6 7 8 9 1 2 look at my way. 3. BY MR. CRITTON: 4 Q. In your view? 5 A. Yes. 6 7 8 9 be true for purposes of this question. Did you ever observe any what you would have seen as emotional trauma or any type of disturbance with C.W. on the many times she came 10 to your house? 11 MR, EDWARDS: Form. 12 THE WITNESS: I didn't see any. 13. BY MR. CRITTON: 14 Q. Does it make sense to you that a person 15 who claims emotional trauma would continue to come Q. So if you looked at -- I don't remember whether Playboy still has -- say a Playboy that has a frontal nudity shot of a woman, you would in essence Say that Playboy is selling pornography? 10 A. Yes. 11 Q. Therefore, every person who buys a 12 Playboy that has over the last umpteen tens of 13 years that has a frontal picture of a woman in the nude would be purchasing pornography whether it's from CVS, or Walgreens, or Eckerd as they existed, backte By dees-tha F at OVO 7 17 sir? 17 18 MS. EZELL: Objection, form. 18 MR, EDWARDS: Form. 19 MR. EDWARDS: Form. 19 MR, HOROWITZ: Form. 20 MR. HOROWITZ: Form. 20 MR. WILLITS: Object to the form of the 21 BY MR. CRITTON: 22 Q. The photographs -- I'm sorry, the 23 pictures that you saw in the computer, I think you 24 were able to draw those up or bring those up from your own computer. 21 question. 22: THE WITNESS: I'm not a psychologist. 23 MR. EDWARDS: Can you state your answer, 24 I didn't hear it? THE WITNESS: Yeah, I'm nota 38 (Pages 415 to 418) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000352 GIUFFRE00 1042