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Case 1:15-cv-07433-LAP Document 1335-4 DCDOMDADUBPWNHNFDWOWOWOAIDUOBWNE Page 94 G Maxwell - Confidential Q. I'm asking the questions. I know what this case is about. I'm trying to -- I will ask you questions if you don't understand the question I can break it down for you. I'm happy to do that. A. Break it down a lot please. Q. Iwill do that. The question is, have you ever said to anybody that you recruit other girls -- A. Why don't you stop there. Q. Let me finish my question. Have you ever said to anybody that you recruit girls to take the pressure off you, so you won't have to have sex with Jeffrey, have you said that? That's the question? A. You don't ask me questions like that. First of all, you are trying to trap me, I will not be trapped. You are asking me if I recruit, I told you no. Girls meaning underage, I already said I don't do that with underage people and as to ask me about a specific conversation I had with language, we talking about almost 17 years ago when this Filed 01/09/24 Page 26 of 106 DMIDHTBPWNHRFPDOANHA UY BWNHE MNNNNND OApBWNHEOW Page 96 G Maxwell - Confidential testify to actual language. Q. So you won't testify to anything I'm asking you 17 years ago about a statement you made. How do you know it's 17 years ago? A. Weare talking about a time in 2000, right? Q. Have you ever said that to anybody? A. I'm 54 years old so you are asking me in my entire life, what words are you asking me in my entire life? Q. Your entire life is limited by the time you were with Jeffrey, this is the question. A. Let's time limit the question you are asking me. Q. So from, let's say, | think you said you started with him in 1992, is that correct, and finished with him in 2009. So from 1992 to 2009 have you ever said to anybody that you recruit other and we will start with girls to take the pressure off you to have sex with Jeffrey? MR. PAGLIUCA: Objection to the form and foundation. Page 95 G Maxwell - Confidential took place. I cannot testify to an actual conversation or language that I used with anybody at any time. Q. Have you ever said to anybody that you recruit other females over the age of 18 to take the pressure off you to having to have sex with Jeffrey? A. I totally resent and find it disgusting that you use the word recruit. I already told you I don't know what you are saying about that and your implication is repulsive. Q. Answer my question. A. Ijust did. Q. Have you ever said to anybody that you recruit females -- A. I don't recruit anybody. Q. That's an answer. So you never said that? A. I'm testifying that I cannot testify to an actual language -- Q. It's a yes or no. A. Iwill not testify to an actual statement made 17 years ago, so I cannot MAGNA® ~— DMIDABWNHROWODAIADAUGUBRWNHE Page 97 G Maxwell - Confidential A. First of all I resent and despise the world recruit. Would you like to define what you mean by recruit and by girls, you mean underage people. I never had to do anything with underage people. So why don't you reask the question in a way that I am able to answer it. Q. I'm asking if you ever said that to anybody. So if you don't understand the word recruit and you never used that word then the answer to that question would be no. A. Ihave no memory as I sit here today having used that word. Q. Did you ever meet an underage girl in London to introduce her to Jeffrey to provide him with a massage? MR. PAGLIUCA: Objection to the form and foundation. A. Run that past me one more time. Q. Did you ever meet an underage girl in London to introduce her to Jeffrey to perform a massage? MR. PAGLIUCA: Same objection. A. Are you asking me if I met anybod: (Pages 94 to 97) LEGAL SERVICES