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Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE Page 194 G Maxwell - Confidential situation, naked as you describe. Q. Did you take a picture of Virginia Roberts on her own without another individual in it in a naked state? A. Idon't recall ever taking a picture of Virginia -- naked, we are not referring to someone with no clothing on at all, we are referring to someone that could be semi clad or could have a towel or we are not referring to anything inappropriate. Q. Was this a hobby of yours to take pictures of the type that you are describing? MR. PAGLIUCA: Object to the form. A. Ijust testified, I didn't take pictures of many people. My preference is pictures for landscapes and for architectural pieces. . Where are those pictures today? . [have no idea. . Do you have them in your home? . Ido not. . Do you have them on your computer? . Ido not. . What has Jeffrey Epstein told you Filed 01/09/24 Page 51 of 106 DIDO BWNFPWOOANDOAWNE Page 196 G Maxwell - Confidential about those things. Q. What has Jeffrey Epstein told you about Virginia Roberts? A. That she is a liar. Q. What does he base that on? MR. PAGLIUCA: Objection to the form and foundation. A. You would have to check with him. I can tell you why I think she is a liar, I'm happy to do that. Q. Did he tell you he did not have sexual relations with Virginia Roberts? A. Ican only testify what I know. Q. I'm asking, has he told you that he did not have sexual relations with Virginia Roberts? A. Ican only tell you what I know about Virginia Roberts, I cannot tell you what he knows about Virginia Roberts. Q. I'm asking, did he tell you that he did not have sexual relations with Virginia Roberts? A. All he told me is she is a liar. Q._ That's all he said about Virginia Page 195 G Maxwell - Confidential about the allegations related to the criminal investigation that he was involved in? A. [really can't say, not because I don't want to say but I just think of what he has said to me over the course of this time. Q. Did he explain it to you and explain what the charges were against him? A. Inever had a detailed conversation with him, as I recall. Q. Not detailed, just did he explain anything that was happening to him? A. Ihaven't spoken to him for so long. I can't possibly testify to what conversations I had with him over the course of time. Q. Did he talk to you about any of the girls that were making allegations against him other than Virginia? MR. PAGLIUCA: Objection to the form and foundation. A. You are talking about the police records again, all of that? Q. Yes. A. Ihave never had a conversation Page 197 G Maxwell - Confidential Roberts? A. We went through all the lies that you have sold to the papers and sold in general and we have analyzed her lies and your lies and your inappropriate behavior in detail. Q. Did he ever say that he did not have sexual relations with Virginia Roberts? A. I just testified that we went through all of her lies. Q. Lunderstand what you said. I'm asking you a question. Did he ever tell you that he never had sex with Virginia Roberts? A. I don't recall whether he ever -- I don't know I ever had that question. We focused on the lies she did say she had with him as relates to me. I don't remember asking him about his problems with her. I'm interested in what she says about myself. Q. Did you also talk about what things that Virginia Roberts was saying that were true? A. There isn't anything that she said 0 (Pages 194 to 197) MAGNA® — LEGAL SERVICES