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Case 1:15-cv-07433-LAP Document 1335-4 DIDO BWNFPWOOANDOAWNE Page 286 G Maxwell - Confidential moment there is such a document, just hypothetically, and assuming for the moment that it is going to get produced somewhere, if it hasn't already been produced, obviously that would involve a waiver, a future waiver of the privilege. I think that's the answer to the question. Q. Has the document been produced, do you know? A. You have everything that I have given you, so if you can't -- if it's not in those documents, I don't know what to tell you. Q. Your lawyers haven't withheld any documents? A. They are right here. You can ask them. Q. I'm asking you. A. I don't know what -- they're lawyers. Q. When we were talking earlier about Prince Andrew, I asked you whether you had ever given him a gift of a puppet. Filed 01/09/24 Page 74 of 106 AIANDUBPWNHrRPOW ADA ATDUOBWNEH Page 288 G Maxwell - Confidential hand puppets, all sorts of puppets. Q. Is there any puppet you've ever seen in Jeffrey Epstein's home in the presence of Prince Andrew? A. Again, puppet, you know, there is lots of types of puppets. Q. Any type of puppet. A. Ifyou want to give me a description of the puppet, I would be perhaps be able to say. Q. Any type of puppet? A. Can you be more detailed? Q. Have you ever seen a puppet in Jeffrey Epstein's home in the presence of Prince Andrew? A. My understanding of a puppet is a small handheld item you have in a circus. I have never seen that. Q. Have you ever seen a puppet which is defined as a movable model of a person or animal that is used in entertainment and typically moved either by strings or controlled from above or by a hand inside it? MR. PAGLIUCA: Objection to the Page 287 G Maxwell - Confidential Did you ever, not as a gift, did you ever see in the presence of Prince Andrew a puppet? MR. PAGLIUCA: Objection to the form and foundation. A. Can you be more direct, please? Q. Sure. Were you ever in a room with Prince Andrew where there was a puppet? MR. PAGLIUCA: Objection to the form and foundation. A. Can you be more specific please and can you bound it by time and be more specific, whatever you are actually asking me? Q. Were you ever in a room with Prince Andrew in New York in Jeffrey Epstein's home where there was a puppet? MR. PAGLIUCA: Objection to the form and foundation. A. What sort of puppet are you asking me? Q. Any kind of puppet? A. You need to be more descriptive. I don't know what you mean by puppet, there is Page 289 G Maxwell - Confidential form and foundation. A. Ihave not seen a puppet that fits exactly that description. Q. Have you seen any puppet that fits any description? MR. PAGLIUCA: Objection to the form and foundation. A. Can you reask the question, please? Q. Yes. Have you seen any puppet that fits any description in the presence of Prince Andrew in Jeffrey Epstein's home? MR. PAGLIUCA: Objection to the form and foundation. A. Iam not aware of any small handheld puppet that was there. There was a puppet -- not a puppet -- there was a -- I don't know how would you describe it really, I don't know how would you describe it. Not a puppet, I don't know how you would describe it. A caricature of Prince Andrew that was in Jeffrey's home. Q. Did you use that caricature to put the hand of the caricature on Johanna 3 (Pages 286 to 289) MAGNA® — LEGAL SERVICES