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Case 1:15-cv-07433-LAP Document 1335-4 DIDO BWNFPWOOANDOAWNE Page 146 G Maxwell - Confidential one of his planes? A. There was a bed on one of his planes that folded out, yes. Q. Do you recall whether with respect to this being in Santa Fe, do you recall whether you were there for some form of a party? MR. PAGLIUCA: Objection to the form and foundation. A. I don't recall the trip at all and this looks like a total work trip, not a party trip. Q. What would be the difference between a work trip and a party trip? A. Just that I would be on trips for work and I believe that this looks like, AP looks like it's one of the -- probably one of the designers and the time would meet with a trip to decorate the house, just the timing of it. Q. So would Virginia be brought on trips that were for the purpose of work and decorating the house? A. Like I said, I never worked with Filed 01/09/24 Page 39 of 106 AIDUAWNHEHRFCOAIADAFOBWNHEHE Page 148 G Maxwell - Confidential excerpts from -- we will identify what they are but from the message pads. Did you want to correct anything? A. I want to make an addendum. Would you mind rereading the last question back to me? (Record read.) A. ILalso just want to say that at this point I cannot recollect flying to parties. Jeffrey went for work so -- was this in Santa Fe, this flight as well. Q. The flight we were looking at, yes but it was to Santa Fe -- A. I don't recall going to any parties in Santa Fe at any time but certainly flying to Santa Fe for a party seems highly improbable. Q. So I'm going to direct your attention to the document that I set before you which is Bates number and it has different Bates numbers because it's a smaller version of the larger production. These are the pages I will be asking about. In the time that you were working Page 147 G Maxwell - Confidential her but you would have to ask Jeffrey what he brought her on the trip for. Q. But she would travel with him when here was a work trip like this? A. Ican't -- I'm seeing that she is on this flight but I have no idea what she is doing, he invited her, it would not be my job. Q. What about ‘would she regularly travel with Jeffrey on flights? A. Thave no idea, you would have to ook through the flight logs. I have no idea. Q. Your recollection is -- what is your recollection, do you recollect raveling often on flights with Jeffrey? A. Absolutely not. No, not at all. I don't recollect her actually on the flight at all. Q. I think you can set that aside for the moment. (Maxwell Exhibit 9, message pad pages, marked for identification.) Q. We will mark as Exhibit 9 these MAGNA® Page 149 G Maxwell - Confidential with Jeffrey in Palm Beach, do you recall a process for taking, anybody at the house taking messages when incoming phone calls came in? A. You are supposed to take a message and receive the message and write the message down. Who was the message was for, what time it was taken and who took it and what the message was, obviously. Q. Does what's in front of you look familiar with respect to the message pads that you would have used at the house? A. It is familiar. Q. I'm going to direct your attention to the second page of it? MR. PAGLIUCA: These all have SAO numbers on them or Bates ranges and I don't see any of your Bates ranges on these. I know you have produced message pads but those have your Bates range numbers on them and I'm wondering if these are different documents. MS. McCAWLEY: It's the same, just ours have the Bates underneath them. 38 (Pages 146 to 149) LEGAL SERVICES