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Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 33 of 73
Confidential
Page 122
G. Maxwell - Confidential
A. Thave not.
Q. You did communicate with
Mr. Epstein after you saw that police report,
correct?
MR. PAGLIUCA: Objection to form
and foundation.
A. I don't know that's true.
Q. When did you see the police report?
MR. PAGLIUCA: If this involves
communications with me, I'm going to
instruct you not to answer the
questions.
Q. Is it your testimony that the only
time you saw the police reports was when it
was shown to you by your counsel?
A. That's the only time I recollect.
Q. What?
A. That's the only time I remember
seeing it.
Q. When did your counsel show you the
police report?
MR. PAGLIUCA: If you remember, you
can answer that question.
A. I don't know. I guess recently,
DMIDTUBWNPFPOCODIDAGVBRWNHE
Page 124
G. Maxwell - Confidential
A. A very long time ago.
Q. How long?
A. I think two years ago, something
like that.
Q. Before this defamation lawsuit?
A. Excuse me?
Q. Before this defamation lawsuit?
A. You are asking if I communicated
with him before the defamation? What are you
asking me?
Q. Have you communicated with
Mr. Epstein since this defamation lawsuit was
filed?
A. Idon't believe I have. I haven't
spoken to him -- no, I don't think so. I
don't remember when it was filed, no, I don't
think so.
Q. By communication, I don't mean just
speaking to him. I mean writing him a
letter, email, communicated in any way?
A. No.
Q. When you say no, does that mean you
have not communicated with Mr. Epstein in any
way since this lawsuit was filed?
Page 123
G. Maxwell - Confidential
but I don't recall.
Q. In the last 30 days?
A. Ireally don't remember when I saw
It.
Q. Was the first time that you saw the
police report sometime this calendar year
2016?
A. I don't remember when I've seen
them. It's in the course of this latest
lies.
Q. What do you mean, in the course of
this latest lies?
A. Inthe course of this defamation
suit.
Q. And you may not be able to answer
this, but if you can, I just want to know.
When you saw the police report in the course
of this defamation suit, was it this calendar
year, that is 2016, sometime?
A. I don't know, I'm sorry, I have no
memory.
Q. When is the last time you had a
conversation or communication with
Mr. Epstein?
Page 125
G. Maxwell - Confidential
A. I don't recall any communications
with him since this lawsuit has been filed.
Q. Did you ever discuss Sarah Kellen
Vickers with Mr. Epstein?
MR. PAGLIUCA: Objection to form
and foundation.
A. I would have had conversations with
him in general terms. Obviously I talked
about her with him but not in any context of
this situation. Just I will have talked to
him about her.
Q. When was the last time you talked
to Mr. Epstein about Sarah Kellen Vickers?
A. Probably in 2003, 2002.
Q. What was the subject matter of that
conversation?
A. Ihave no idea.
Q. Did it have anything to do with
Mr. Epstein's relationship with Sarah Kellen
Vickers?
A. No, Ihave no idea. It would have
nothing to do with anything other than a
work-related issue.
Q. Did Sarah Kellen Vickers work for
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Document Details
| Filename | Giuffre_Maxwell_Batch8_p00499.png |
| File Size | 524.1 KB |
| OCR Confidence | 94.1% |
| Has Readable Text | Yes |
| Text Length | 3,236 characters |
| Indexed | 2026-02-04 12:50:36.510667 |