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Case 1:15-cv-07433-LAP Document 1335-4 AIDUAWNHEHRFCOAIADAFOBWNHEHE Page 26 G Maxwell - Confidential and foundation of the question. A. First of all, can you break the question apart. Q. Have you used the phrase the younger the better in speaking to Ms. Roberts and asking her to recruit females for Jeffrey Epstein? MR. PAGLIUCA: Object to the form and foundation. Q. You can answer. It's yes or no. A. No, that's absolutely not true, on the second part of your question, I have not asked Virginia to recruit females and the first part of your question, if you can repeat that again, the question you asked. Q. Will you read back the question. (Record read.) A. Ibelieve I answered the later part of the question. The first part of the question, it's impossible for me to recall events that took place 16 years ago but it doesn't sound like something I would say. Q. On page 28, that same paragraph, Roberts was asked how many girls in total she Filed 01/09/24 Page 9 of 106 SCUOMIDUBAWNHEOWCAIAAOAWNHE MNNNNN Owe wn Page 28 G Maxwell - Confidential A. First of all, as I said when I was present -- Q. Itis ayes or no. A. No, it is not. Q. You can answer the question in full but please provide yes or no as an initial matter. A. I cannot answer yes or no, it's not bounded by time. It's entirely possible I could have been in a room or even in the vicinity of Palm beach when somebody came and I would not know. How would I know when somebody was in the house. There is no way I can know. Q. Did you stay at Jeffrey Epstein's home when you were in Palm Beach? A. Most of the time. Q. So how is it that you wouldn't know if there was a female in the home under the age of 18 if you were staying there? A. Well, first of all, when I was staying there, the house is actually quite large and I have a very busy job and I had an office with a door so the door would be shut Page 27 G Maxwell - Confidential brought to Epstein. Robson stated that she can remember, Robson stated that she brought and, it's redacted there, and the victim in this case. Let me ask my question, I have a question pending right now. Are you testifying that you are unaware of any underage, under the age of 18, females coming to Jeffrey Epstein's home to perform massages? MR. PAGLIUCA: Object to the form foundation. A. You need to straddle that question in a different time period. When I was there, at the time I was present, the people that gave Jeffrey, men and women who gave Jeffrey massages were adults over the age of 18. Q. Never in your time at any of Jeffrey Epstein's homes were you present when a female under the age of 18 was there to give Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form and foundation. MAGNA® DAIANDUBWNHRFPOWOWAAINDUOBWNH Page 29 G Maxwell - Confidential and I would be working. I'm not responsible for what Jeffrey does and I don't always pay attention to what happens in the house. I'm very busy. Q. So you're testifying that you never observed a female under the age of 18 at Jeffrey Epstein's West Palm Beach home? MR. PAGLIUCA: Object to the form and foundation. A. lalready answered that question, I believe. Q. You didn't answer my question. A. Idid. Q. Did you observe a female under the age of 18 at Jeffrey Epstein's home in Palm Beach? A. Like I said, I work, I don't sit there and watch people coming in and out of the house. I cannot possibly tell you if I'm in the home that somebody was there that I did not see, I cannot comment on it, I have no idea. Q. Did you observe females at Jeffrey Epstein's home that were laying out topless 8 (Pages 26 to 29) LEGAL SERVICES