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Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWODIA UY AWNHE Page 190 G Maxwell - Confidential or around the home? A. I think we need to distinguish between anyone under the age of 18 and over the age of 18. Q. We will start with, did you take pictures of nude females in or around any of Jeffrey's homes of women or females that were under the age of 18? A. No. Q. Did you take pictures of nude females -- A. Nude you mean with no clothing on. Q. Or half nude, with no top on, any sort of nakedness to an individual. In any of Jeffrey's homes, either Palm Beach, New Mexico, USVI or New York either outside by the pool, anywhere in or around those homes of females over the age of 18? A. So it is possible that I took pictures of people that were somehow semi or had some clothing on or no clothes on but at no time were any of these pictures remotely inappropriate. They were, you could see them Filed 01/09/24 Page 50 of 106 DIDO BWNFPWOOANDOAWNE Page 192 G Maxwell - Confidential Q. Notas a gift. Do you recall ever giving Jeffrey Epstein pictures that you've taken of these individuals in a naked state? MR. PAGLIUCA: Objection to the form and foundation. A. First of all, we've already established that they are not naked state photographs. Q. A piece of them being naked as you described. A. I said they would be attractive as you would see in mainstream magazines and those pictures could be a picture of a hand or a foot, they didn't necessarily constitute -- I know where you are headed with this and it's nowhere appropriate and it's really unattractive. Q. I'm not headed anywhere. I'm just asking the questions. Did you give Jeffrey Epstein any of these pictures that you took of females in the state that you described? A. Ican't recall ever giving him pictures but it is possible that I took Page 191 G Maxwell - Confidential in a mainstream magazine today, there would be no inappropriateness, they would be covered, concealed, you wouldn't see anything at all. The types of -- first, I took very few and they were always by request, this was a picture you could put on your -- gift to your parent or to your grandparents to put on their mantel piece . It would be a very benign sort of attractive picture where you wouldn't see anything. Q. Who would request those pictures? A. From time to time, people, men and women would ask to have nice photographs of them taken. Q. And did Jeffrey Epstein request those pictures? A. I don't ever recall him asking me to take pictures. Q. Did you give him pictures of naked females as a present? A. I don't recall ever giving a present of -- I don't know why a photograph would constitute a gift. Page 193 G Maxwell - Confidential pictures of people that would end up -- or a friend of his that he would have -- not naked or not inappropriate in any way, that he might have somewhere in his house. Q. Name for me all the individuals who you took these pictures of? A. It's entirely impossible for me to name people. First of all, it was just -- it would not be possible, I took thousands of photos, not of people, I mostly take pictures of landscapes and things. I have no recollection specifically of people that I took pictures of. Q. So you can't remember, is it your testimony you can't remember one person that you took a picture of in either a naked or semi naked state? A. Iseriously cannot recall. I just don't recall. Q. Did you take a picture of Virginia Roberts either alone or with another individual in a naked state? A. Ihave never taken, I believe, any pictures of two people in any type of 9 (Pages 190 to 193) MAGNA® ~ LEGAL SERVICES