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Case 1:15-cv-07433-LAP Document 1335-4 DAIDUBPWNFPOOAIAGTBRWNHE Page 90 G Maxwell - Confidential assaulted by Jeffrey Epstein during the time you were working there? A. Based on the lies that I have already been told, I cannot comment on any -- Q. Are you saying these 30 girls are lying when they gave these reports to police officers? A. I'm not testifying to their lies. I'm testifying to Virginia's lies. Q. Iam not asking about Virginia's lies. A. Ican only testify to Virginia's lies. I can testify to having read these reports. I cannot testify to anything else about them. Q. So your testimony is that during the time you were working there, you did not know that these minor children were being abused in the home while you were there? A. What I have already told you and I will repeat, I was in the house very limited times, very few times. I do not know what you are referring to. I've read these reports but based on the lies that Virginia Filed 01/09/24 Page 25 of 106 DMIDMNAHBWNHRFPOWODIA UY AWNHE Page 92 G Maxwell - Confidential Q. In your responsibilities in working for Jeffrey, would you book massages for him on any given day so that he would have a massage scheduled? Would you take a call for example and book a massage for him? MR. PAGLIUCA: Objection to the form and foundation. Q. You can answer. A. Typically, that was not my responsibility. He would either book the massage himself or one of his other assistants would do that. Q. From time to time you had to do that? MR. PAGLIUCA: Objection to the form and foundation. A. Like I said, typically it was somebody else's responsibility. Q. If you were unable to book a girl for a massage on a given day, would that mean that you were responsible for giving him a sexual massage? MR. PAGLIUCA: Objection to the form and foundation and I instruct you Page 91 G Maxwell - Confidential has perpetrated, cannot tell you what is true or factual or not. Q. You said you were in the home a very limited time, so average in the year for example, 2004, how many times would you have been in his Palm Beach home? A. Very hard for me to state but very little. Q. How about his New York home? A. Same. Q. Were you his girlfriend in that year, in 2004? A. Define what you mean by girlfriend. Q. Were you ina relationship with him where you would consider yourself his girlfriend? A. No. Q. Did you ever consider yourself his girlfriend? A. That's a tricky question. There were times when I would have liked to think of myself as his girlfriend. Q. When would that have been? A. Probably in the early '90s. MAGNA® Page 93 G Maxwell - Confidential not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that question? A. You just heard my counsel. Q. Have you ever said to anybody that recruiting other girls to perform sexual massages for Jeffrey Epstein takes the pressure off you? MR. PAGLIUCA: Object to the form and foundation. A. Repeat the question and break it out. Q. Have you ever said to anybody that you recruit girls -- A. Stop right there. I never recruited girls, let's stop there. Now breakdown the question. Q. Have you ever said to anybody -- A. By girls, we are talking about underage people -- you said girls, are you talking about underage -- we are not talking about consensual acts -- this is a defamation suit. 24 (Pages 90 to 93) LEGAL SERVICES