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Case 1:15-cv-07433-LAP Document 1335-4 DIDO BWNFPWOOANDOAWNE Page 198 G Maxwell - Confidential that was true. Q. Nothing she said that you are aware of is true? A. I think she is correct when she talks about what her name is. Q. Anything else? A. I'msure there must be one or two other details but they are so far and few between, I would have to look in detail at all of her allegations to pinpoint what possibly could be true. Q. Did you ever ask Jeffrey if he had sex with minors? A. Ihave never been asked that question. Q. You never asked him that question. What analysis did Jeffrey do to determine that the statements Virginia Roberts were making were lies? MR. PAGLIUCA: Objection to the form and foundation. A. Ask me again, please. Q. What analysis did Jeffrey do to determine that the statements that Virginia Filed 01/09/24 Page 52 of 106 DIDO BWNFPWOOANDOAWNE Page 200 G Maxwell - Confidential communications subject to a joint defense agreement or common interest agreement, I'm telling her not to answer. To the extent she has information outside of those things, she is permitted to answer. Q. Do you understand? So if it was a conversation with a lawyer which I'm not asking about, I don't want you to tell me about your conversations with lawyers. I want you to tell me whether Jeffrey Epstein ever told you what he analyzed in order to determine which of -- of what Virginia were saying were lies? A. Ido not know what he did, no. So you agree she is lying, Singrid. Q. Ido not agree with that and I'm asking the questions. A. You just said her lies. Q. I'm repeating a statement you made. Q. Are you saying it's an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was Page 199 G Maxwell - Confidential Roberts were making were lies? MR. PAGLIUCA: Objection to the form and foundation. And to the extent that any of this answer calls for any privileged communication, I'm instructing, with myself or another lawyer representing you or in any common interest agreement, I'm instructing you not to answer. MS. McCAWLEY: The court ruled she is entitled and you had to produce documents about communications with Jeffrey, that's what I'm asking about. I'm not asking about communications with lawyers. Q. I'm asking what analysis did Jeffrey do to determine that the statements that Virginia Roberts was making were lies, if you know? MR. PAGLIUCA: My objection is to the extent she learned any of that information as a result of either a privileged communication from a lawyer, one of her lawyers or a privileged Page 201 G Maxwell - Confidential underage? A. Ican only testify to what I saw and what I was present for, so if you are asking me what I saw then I am happy to testify. I cannot testify to what somebody else did or didn't do. Q. Did you issue a statement to your press agent, Ross Gow in 2015, stating that Virginia Roberts' claims were, quote, obvious lies? MR. PAGLIUCA: Objection to the form and foundation. Q. You can answer. A. You need to reask me the question. Q. Sure. Did you issue a press statement through your press agent, Ross Gow, in January of 2015, stating that Virginia Roberts' claims were, quote, obvious lies? MR. PAGLIUCA: Objection to the form and foundation. A. Can you ask it a different way, please? I will ask it again and you can 98 to 201) MAGNA® =" LEGAL SERVICES