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Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 32 of 73 Confidential Page 118 G. Maxwell - Confidential massages or sexual activities? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. When was the last time you had any communications with Sarah Kellen Vickers? A. A long time ago. So long, I don't recall. Q. Were you aware that Sarah Kellen Vickers was noticed for a deposition in this case? A. I believe I did know that, yes. Q. Did you have any conversations with anyone as to whether or not Sarah Kellen Vickers would or should show up for that deposition? MR. PAGLIUCA: Wait a minute, what does that have to do with the court's order. Don't answer that question. Just don't answer it. This is silly. MR. BOIES: I actually think it is far from silly. I think it goes to an obstruction of justice situation that I think you would be well advised to allow DMIDTUBWNPFPOCODIDAGVBRWNHE Page 120 G. Maxwell - Confidential at all improper. I am not making any assertions. I'm simply asking questions. I'm trying to find out what the facts are. MR. PAGLIUCA: No, you are not. MR. BOIES: Yes, lam. You are trying to keep the facts from coming out. MR. PAGLIUCA: No, I'm not. I'm trying to keep this orderly and not abusive as to where it is going. MR. BOIES: This is so far from abusive. MR. PAGLIUCA: I think we should take a lunch break, given it is noon. MR. BOIES: We will do it in a half hour, I want to finish this line of questioning. I will guarantee we are out by 12:30. BY MR. BOIES: Q. Let me ask you about a few other people. Nadia Marcinkova, do you know her? A. Ido. Page 119 G. Maxwell - Confidential your client to answer the question on. MR. PAGLIUCA: Do you have a good faith basis to suggest that she suggested that Ms. Kellen not show up at her deposition yesterday? MR. BOIES: I don't know whether it was you, I don't know whether it was her, I don't know who did it. What I do know is that she didn't show up, and I think the evidence will be quite clear that your client's testimony about the extent of her relationship with Sarah Kellen Vickers is not accurate. And in that context, I think the circumstances under which it turns out that she doesn't show up is entirely appropriate for examination, but that is something that I'm happy to talk to the judge about. MR. PAGLIUCA: Sure. And I hope that you give him some good faith basis for the assertions that you are making here today, which are wholly improper. MR. BOIES: I don't think they are Page 121 G. Maxwell - Confidential Q. Is she anyone with whom Mr. Epstein had sex? MR. PAGLIUCA: Objection to form and foundation. A. [have no idea. Q. Is she anyone with whom Mr. Epstein engaged in sexual activities? MR. PAGLIUCA: Objection to form and foundation. A. Ihave no personal knowledge. Q. When you say you have no personal knowledge, what do you mean by personal knowledge? A. I mean that I've read the police reports, so that's the only knowledge I have of what Nadia or anybody else has with Jeffrey. I have no way of knowing whether they did or not. Personal knowledge means did I know myself. Q. After you saw the police reports about Mr. Epstein's relations with Nadia Marcinkova, did you ever talk to Mr. Epstein about whether or not that police report was or was not accurate? MAGNA®© 31 (Pages 118 to 121) LEGAL SERVICES