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Case 1:15-cv-07433-LAP Document 1335-4 MIDNA HBRWNHRFPDOWOCAIAUYAWNHE Page 150 G Maxwell - Confidential These were produced as part of the rule 26 discovery. We can get the additional Bates if you want. Q._ The one I'm asking about first is the You can look at that and then I will identify the Bates number referenced in this case. I want to direct your attention to the top right-hand corner just so I have an understanding of how these messages were taken. So I see that it says at the top it says in the for line it says Ms. Maxwell and the date of 4/25/04 and then I see under the M line it looks like Necole Hesse or something like that, a phone number and a message saying returning your call and on the bottom it looks like = Explain to me, is this -- does this represent Rushi taking down a message for you from Ms. Hesse, is that how these work? MR. PAGLIUCA: Objection to the form and foundation. Go ahead. Q. My question is, I'm trying to understand how the messages were taken. Filed 01/09/24 Page 40 of 106 MIDNDHBWNHEFOCHODAID OV BAWNHE NM NM NNN NY OwpWNEROLW Page 152 G Maxwell - Confidential for JE, date 1/02/03, message Caroline Casey and then it's signed GM. Is that your signature? A. That's not my handwriting. Q. Would other people take a message, how did this process work, is there someone else in the house with the initials GM? MR. PAGLIUCA: Objection to the form and foundation. A. I cannot answer that. It's not my handwriting. Q. I'm trying to understand how this gets there. If you took a message and didn't write it down, would someone else record that message for you? MR. PAGLIUCA: Objection to the form and foundation. A. AllIcan tell you, this is not my handwriting so I cannot -- I have no idea what that is. Q. Was the practice that, what was the practice when someone answered the phone with these message pads, what were they supposed to do? Page 151 G Maxwell - Confidential Looking at this message pad, where it says signed can you tell me who was? A. Icannot. Q. You do not know. Typically when these messages were taken in your practice when you were there, would the individual who took the message write their name on the message? MR. PAGLIUCA: Objection to the form and foundation. A. I don't recollect, you can ask who wrote it so you can find out who it was. Q. Do you know who Necole Hesse is? A. I don't. Q. I'm going to direct your attention -- do we have a Bates number for that? MR. EDWARDS: Q. Giuffre for that one. I will direct your attention to the first page which has the on it. A. Okay. Q. Now at the top of that document, on the right-hand side, the message that reads MAGNA® DMIDAHBWNHROCWODAIDDGOAWNHE NNNNNNDN OB WwNHrROW Page 153 G Maxwell - Confidential A. They were supposed to take a message and the time and date and give the message. Q. Were they supposed to indicate who took the message? A. They were but it wasn't -- I don't really recall the actual process. I can see from here it looks like you were supposed to but that's not my handwriting so I can't say what that was. Q. Do you know who Caroline Casey is? A. No, I don't. Q. Do you know whether Caroline Casey was under the age of 18? A. I just testified I couldn't remember who she was so it would be difficult to know how old she was. Q. Do you know if she was coming to the house to provide massages? A. I don't remember who she is at all, so no. Q. And then I would like to direct your attention to the message rig underneath it. Which says JE, 39 (Pages 150 to 153) LEGAL SERVICES