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Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE Page 50 G Maxwell - Confidential A. People had salaries and they were paid by the office. Q. Did you ever pay any individual, did you ever hand an individual cash for work they performed? MR. PAGLIUCA: Object to the form. A. Can you be more specific about what you are asking me. Q. Did you ever hand any individual who was working at the home cash as payment for something that they performed at the home? MR. PAGLIUCA: Object to the form. A. To the best of my recollection there were very few times where I would leave some cash for people for work performed. Q. And what type of work was being performed where you would be doing that? A. IfI left cash for the pool guy, I would have left potentially some cash for the gardener, potentially for exercise instructors and sometimes for massage therapy. Q. How much were the massage Filed 01/09/24 Page 15 of 106 MIDNA HBRWNHRFPDOWOCAIAUYAWNHE Page 52 G Maxwell - Confidential for sexual acts. Q. I'm asking if they performed sexual acts? MR. PAGLIUCA: Object to the form and foundation. Q. Did any of the massage therapists who were at the home perform sexual acts for Jeffrey Epstein? A. I don't know what you mean by sexual acts. Q. Did any of the massage therapists who were working at the home perform sexual acts, including touching the breasts, touching the vaginal area, being touched while Jeffrey is masturbating, having intercourse, any of those things? MR. PAGLIUCA: Objection. Form and foundation. To the extent any of this is asking for to your knowledge any consensual sex act that may or may not have involved you, I'm instructing you not to answer the question. Q._I'm not asking about consensual sex Page 51 G Maxwell - Confidential therapists paid? MR. PAGLIUCA: Object to the form and foundation. A. They get paid between 100 and $200. Q. Did it vary based on what sexual acts they performed? MR. PAGLIUCA: Object to the form and foundation. A. No. It varied depending how much time, some massage therapists charge more and some charge less. Q. Did the massage therapists that were hired to come to the home perform sexual acts for Jeffrey Epstein? MR. PAGLIUCA: Object to the form and foundation. A. What are you asking me? Q. I'm asking if the massage therapists -- A. Are you asking me about underage girls? Q. I'm asking in general, did any of the massage therapists in the home -- A. Are you asking if they were paid MAGNA® Page 53 G Maxwell - Confidential acts. I'm asking whether any of the massage therapists performed sexual acts for Mr. Epstein, as I have just described? A. Ihave never seen anybody have sexual intercourse with with Jeffrey, ever. Q. I'm not asking about sexual intercourse. I'm asking about any sexual act, touching of the breast -- did you ever see -- can you read back the question? (Record read.) A. I'm not addressing any questions about consensual adult sex. If you want to talk about what the subject matter, which is defamation and lying, Virginia Roberts, that you and Virginia Roberts are participating in perpetrating her lies, I'm happy to address those. I never saw any inappropriate underage activities with Jeffrey ever. Q. I'm not asking about underage. I'm asking about whether any of the masseuses that were at the home perform sexual acts for Jeffrey Epstein? A. Ihave just answered the question. Q. No, you haven't. 14 (Pages 50 to 53) LEGAL SERVICES