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Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE Page 238 G Maxwell - Confidential Q. Task the questions, you answer. If you can't answer, you can say I don't know. But my question is, do you agree that it's psychologically harmful to have sex with a minor? MR. PAGLIUCA: Objection to the form and foundation. A. Are you giving me a random question and as not relates to this case and not relates to anything. It's obviously not something that you want to have happen. Q. Do you agree that Jeffrey Epstein has harmed many minors by having sex with them? MR. PAGLIUCA: Objection to the form and foundation. A. I can't testify to what Jeffrey did or didn't do. I have no knowledge of what you are asking me. Q. If Jeffrey had sex with minors, would you agree that that could harm a minor? MR. PAGLIUCA: Object to the form and foundation. Filed 01/09/24 Page 62 of 106 SCODMDIADUBWNHKFOWDAIUAYOBWNHER Page 240 G Maxwell - Confidential harm. MR. PAGLIUCA: Object to the form form and foundation. A. I would like to say all the terrible things Virginia Roberts said about me is extremely harmful and you should turn that around. All the lies she has said and you have backed her on have been extremely damaging to me. So what I can testify to is that somebody who has made these outrageous allegations and who is a serious liar and that I know for a fact is a liar, that I can testify is damaging to me. Q. Do you agree that calling a sexual abuse victim a liar when she speaks out about her abuse can cause psychological harm? MR. PAGLIUCA: Are you asking a hypothetical question? MS. McCAWLEY: Yes. A. You are asking me to speculate? Q. I'm not asking you to speculate . If somebody is a sexual abuse victim -- A. Ican't testify to what some random Page 239 G Maxwell - Confidential A. Again, I am not testifying to what Jeffrey did or did not do because I cannot. Q. You don't know whether Jeffrey Epstein ever had sex with a minor? A. Again, I cannot testify to what Jeffrey did or didn't do. I cannot. Q. You never observed him having sex with a minor? A. Inever observed Jeffrey having sex with a minor. Q. Do you agree that calling a sex abuse victim a liar when she speaks about her abuse can cause psychological harm? MR. PAGLIUCA: Objection to the form and foundation. A. Can you repeat the question. Q. Do you agree calling a sex abuse victim when she speaks about her abuse can cause psychological harm? MR. PAGLIUCA: Objection to form and foundation. A. Say it again. Q. Do you agree that calling a sexual abuse victim a liar can cause psychological Page 241 G Maxwell - Confidential hypothetical person that you are asking me to speculate on their mental state or health versus speculative statement. I can't do that, that's just not right. Q. Do you agree that by calling Virginia Roberts a liar when she was subject to sexual abuse by Jeffrey Epstein can cause psychological harm? MR. PAGLIUCA: Objection to the form and foundation. Assumes facts not in evidence. A. Ican only tell you about what I know of Virginia's lies. She lied repeatedly, often and I know for a fact she is a liar so I can only testify to what I know and the fact that she has lied about me from the beginning to the end and repeatedly causes me to question anything that she may feel. Q. Is it an obvious lie you had sex toys in Jeffrey Epstein's Palm Beach house? MR. PAGLIUCA: Objection to the form and foundation. A. Can you repeat the question, 61 (Pages 238 to 241) MAGNA® LEGAL SERVICES