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Case 1:15-cv-07433-LAP Document 1335-4 MIDNDHBWNHEFOCHODAID OV BAWNHE Page 246 G Maxwell - Confidential lots of different types of people. In terms of whatever -- very small part of my job, Jeffrey enjoyed getting massages. I think hat is something we can all agree in this room and within the context of that, very infrequently I would go to spas and myself happily receive a professional nonsexual massage from a man and/or from a woman and if, hat massage was something that I thought was something that was good, I would ask if that man or woman would come back and does home visits. If that person said that they did, hey would sometimes come, from time to time, not always, come back to the house to perform a nonsexual professional male or female massage. Q. Were any of the exercise instructors you hired under the age of 18? A. Again, I don't hire, we've already established that I don't hire people. I interview people to see if they are competent in the job that they do and/or whether they are someone who seemed that they can do home visits. Filed 01/09/24 Page 64 of 106 SCUEMIDTUBAWNHEHOWCAIAAOAWNHE NMNNNNN Owe wn G Maxwell - Confidential of 18? A. I think we can establish what adult would be. Q. You never interviewed or I know you don't want to use the word hired, whatever your role was, you brought in an exercise instructor that was under the age of 18 to work at the house? MR. PAGLIUCA: Object to the form and foundation. A. Thave already testified that what I was responsible for was to find people who had competencies in whatever area I was looking for. The competencies I was looking for were professional and adult. Q. So there was no exercise instructor that worked at the Palm Beach house or the New York house or the New Mexico house or the USVI under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. Ican only testify to when I was at the house. Q. Yes. Page 247 G Maxwell - Confidential At the point where I think that there is somebody that has, can be either whatever the job may be, pool, gardener, chef and/or exercise instructor and I think they could be good at whatever it is at whatever skill that they had and they did a home visit which would obviously be mandatory and Mr. Epstein would meet with them and decide if he wanted to have whatever skill it was that he would do it and then he would then either have them come back or hire them. Q. Were there any exercise instructors that worked at the home that were under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. Again, I keep coming back to this, that the people that I employed or -- not the right word, the people I would meet to come and work at the house, under any guise whatsoever, again, from any of the many positions that I filled, were all over -- were adults. Q. When you say adults, over the age MAGNA® DAIANDUBWNHRFPOWOWAAINDUOBWNH MNMNNN NM OPWNHrROW Page 249 G Maxwell - Confidential A. Ican only testify to the years when I was present. Q. Right. A. And I can also only testify to people I personally either met and/or worked with and/or invited, to find the correct word, I don't know what the correct word is, to come to do exercise or whatever it was at the house. Of the people that I, male and/or female that I brought were all appropriate and age appropriate adults. Q. Over the age of 18? A. We've established them as an adult. Q. You are saying appropriate adults, so we are clear, you didn't hire or bring in or know of any exercise instructors that were under the age of 18 at any of those homes? A. Iam also testifying that when I was present at the house and with the people that I brought in, were all age appropriate adults. Q. How do you define age appropriate adults, is that over the age of 18, can we 63 (Pages 246 to 249) LEGAL SERVICES