Giuffre_Maxwell_Batch8_p00769.png

Case 1:15-cv-07433-LAP Document 1335-4 AIDUAWNHEHRFCOAIADAFOBWNHEHE Page 18 G Maxwell - Confidential meet Mr. Epstein? MR. PAGLIUCA: Object to the form and foundation. Q. You can answer. A. Ijust explained. A. Ispent the entire time talking to Virginia's mother outside the house so the answer to the question is no. Q. No, did you not walk her up and introduce her to Mr. Epstein? A. Ijust said no. Q. Did you participate in a massage this first time when she first came to the home and you were speaking with her mother, she was in the home, is that correct, you brought her into the home? MR. PAGLIUCA: Object to the form and foundation. A. Iwill repeat again, I was standing outside with her mother so very difficult for me to do anything else at that time so no, I did not take her upstairs. Q. Did you participate -- A. Virginia lied 100 percent about Filed 01/09/24 Page 7 of 106 MIDNA HBRWNHRFPDOWOCAIAUYAWNHE Page 20 G Maxwell - Confidential you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, I'm going to instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition. MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions. MR. PAGLIUCA: I disagree and you Page 19 G Maxwell - Confidential absolutely everything that took place in that first meeting. She has lied repeatedly, often and is just an awful fantasist. So very difficult for anything to take place that she repeated because I was with her mother the entire time. Q. So did you have -- did you give a massage with Virginia Roberts and Mr. Epstein during the first time Virginia Roberts was at the West Palm Beach house? MR. PAGLIUCA: Object to the form and foundation. Q. Yes or no? A. No. Q. Have you ever given a massage with Virginia Roberts in the room and Jeffrey Epstein? MR. PAGLIUCA: Object to the form and foundation. A. No. Q. Have you ever given Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct MAGNA® DAIAINDUBPWNHRPOWODAIDUBWNHEHE Page 21 G Maxwell - Confidential understand the bounds that I put on it. MS. McCAWLEY: No, I don't. I will continue to ask my questions and you can continue to make your objections. Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female? MR. PAGLIUCA: Objection. Do not answer that question. Again, to the extent you are asking for some sort of illegal activity as you've construed in connection with this case I don't have any problem with you asking that question. To the extent these questions involve consensual acts between adults, frankly, they're none of your business and I will instruct the witness not to answer. MS. McCAWLEY: This case involves sexual trafficking, sexual abuse, questions about her having interactions with other females is relevant to this case. She needs to answer these 6 (Pages 18 to 21) LEGAL SERVICES