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Case 1:15-cv-07433-LAP Document 1335-4 DIDO BWNFPWOOANDOAWNE Page 178 G Maxwell - Confidential What I'm asking you is whether you believe Jeffrey Epstein abused minors? MR. PAGLIUCA: I object to the form and you made your record, she answered the question. A fair reading of her answer is she doesn't have a belief because she doesn't have any personal knowledge. MS. McCAWLEY: Now you are testifying for the witness. Let her answer the question. MR. PAGLIUCA: It's a fair answer to the question. A. Again, I testified my only personal knowledge concerns Virginia and everything Virginia has said is an absolute lie, which is why we are here in this room. If you are asking me to testify about things I have no knowledge of other than the police report that you showed me, I am not in a position to make a statement based on that because you are asking me to speculate and I cannot speculate. Q._I'm asking you about your belief. Filed 01/09/24 Page 47 of 106 DCDOMDADUBPWNHNFDWOWOWOAIDUOBWNE Page 180 G Maxwell - Confidential said is a lie. Therefore, based on those lies I cannot speculate on what anybody else did or didn't do because if Virginia is the example of what that story is and everything she said is false, so everything that leads from that is false. Q. So the 30 other minor children in the police report are also telling lies about being sexually abused during massages with Mr. Epstein? MR. PAGLIUCA: Objection to the form and foundation. Counsel, can you show me in these police reports who the 30 minors are? MS. McCAWLEY: I'm asking my question. MR. PAGLIUCA: You are making a representation about numbers, you are making a representation on the record about what people said or didn't say. We have no knowledge about that. These are all redacted records so these are bad questions. They don't lead to any admissible evidence. It is only being Page 179 G Maxwell - Confidential I'm not asking you to speculate at all. I'm asking what you believe. A. You are asking me to speculate and I won't speculate. Q. I'm not asking you to speculate. I'm asking what you believe. MR. PAGLIUCA: She answered the question and we can move on. MS. McCAWLEY: She hasn't answered the question. MR. PAGLIUCA: We are not going to engage in this debate. She answered the question. If you want to mark it and move to compel an answer to the question, have at it. Okay. Q. Ms. Maxwell, is it your belief that Jeffrey Epstein interacted sexually with minors? A. Again, you are asking me the same type of question exactly but with different language. Again, my only knowledge of somebody who claims these things that I have personal knowledge of is Virginia. Virginia is an absolute liar and everything she has Page 181 G Maxwell - Confidential propounded to the witness to harass her. So we are done with these questions. MS. McCAWLEY: Are you done? MR. PAGLIUCA: Yes. Q. My question is, are you aware that Jeffrey Epstein was convicted of having relations with a minor child? MR. PAGLIUCA: She answered that question already. MS. McCAWLEY: I'm getting to my next question. MR. PAGLIUCA: Ask your next question. Don't keep asking the same question. MS. McCAWLEY: You are now shouting, I want the record to reflect that you are interrupting the deposition. I ask you to calm down, take a deep breath and please let me ask my questions. MR. PAGLIUCA: Your behavior is inappropriate. Q. Iwill ask you again. Do you believe that Jeffrey Epstein 6 (Pages 178 to 181) MAGNA® ~ LEGAL SERVICES