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Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 49 of 73
Confidential
Page 186
G. Maxwell - Confidential
Tila Davies, which of Mr. Epstein's
residences did you see Tila Davis at?
A. I don't have a memory of Tila,
where I would have seen her.
Q. Did you see her at some residence
or property?
A. Idid.
Q. Of Mr. Epstein?
A. Idid.
Q. You just can't remember which ones,
is that fair?
A. Yes, that's fair.
Q. Tiffany Gramza, which residences of
Mr. Epstein did you see Tiffany at?
A. I don't actually recall meeting
Tiffany, so I can't recall.
Q. So Tiffany Gramza may be somebody
who you never met, is that your testimony?
A. No, I'm not saying that. I just
don't recall her really at all. I'm sorry, I
don't recall.
Q. Did you see Tiffany at some
residence or property of Mr. Epstein?
A. Idon't recall.
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Page 188
G. Maxwell - Confidential
not to answer these questions anymore.
These do not appear -- I let this go on,
they don't appear to be tied to the
court's order as relating to sex or
massages or anything that's contained in
the order. This is just simply what was
somebody doing at some property at some
point in time. So don't answer these
questions.
Q. Itis your assertion that, leaving
Mr. Epstein aside, none of the people on this
list engaged in sexual activities with either
you or Mr. Epstein, correct?
MR. PAGLIUCA: Objection to form
and foundation.
A. Ican only testify to myself. I
cannot testify to Mr. Epstein.
Q. With respect to Mr. Epstein, do you
know, one way or another, whether any of
these people engaged in sexual activities?
A. With respect to Mr. Epstein, how
would I know that?
Q. The answer is lots of ways, but all
I can do is ask you whether you know it or
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G. Maxwell - Confidential
Q. Clara Hazel, what properties of
Mr. Epstein did you see Clare Hazel at?
A. Palm Beach, and I believe New
Mexico and New York.
Q. And Melinda Luntz?
A. Palm Beach, I believe.
Q. And what was Melinda Luntz doing at
Palm Beach when you saw her?
A. IfI remember correctly, she was a
real estate broker.
Q. Did you see Melinda Luntz at
Mr. Epstein's Virgin Island property?
A. I don't recall.
Q. When you saw Clare Hazel in Palm
Beach and New Mexico and New York, what was
she doing?
. Idon't know.
. Do you know why she was there?
. I think she was just a friend.
. A friend of Mr. Epstein's?
. Yeah.
. Alexia Wallaert, what Epstein
properties did you see her at?
MR. PAGLIUCA: I will now tell you
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G. Maxwell - Confidential
not.
A. Idon't.
Q. Do you have any reason to believe
-- because I don't want to get stuck on your
concept of personal knowledge -- do you have
any reason to believe that any of the people
on this list had sexual activities with
Mr. Epstein?
A. Ido not.
Q. Do you have any reason to believe
that any of these people had massages at any
Epstein property?
A. Ihave no idea. It's entirely
possible, but I have no idea.
Q. Do you have any reason to believe
that any of the people on this list, other
than Mr. Epstein himself, engaged in sexual
activities with anyone on Mr. Epstein's
properties?
A. Thave no reason to believe that.
Q. Let me go to the Dubin residence.
I asked you some questions about the Dubin
residence earlier and about a possible visit
to that residence of a
MAGNA®© 48 (Pages 186 to 189)
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| Filename | Giuffre_Maxwell_Batch8_p00515.png |
| File Size | 540.5 KB |
| OCR Confidence | 94.3% |
| Has Readable Text | Yes |
| Text Length | 3,406 characters |
| Indexed | 2026-02-04 12:50:45.047128 |