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Case 1:15-cv-07433-LAP Document 1335-4 AINDTHBWNHROWOANIDA YAWNHE Page 298 G Maxwell - Confidential recall the exact conversation. Q. Does Jeffrey Epstein send you text messages? A. No. Q. Do you send him text messages? A. No. Q. How many phone calls have you had with Jeffrey Epstein since December 30, 2014? A. Again, very few. Q. More than five? A. Probably as many as the few emails that I would characterize, so just very few. I mean a small number. Q. Are you aware of any disagreement between your views about Virginia Roberts and Jeffrey's views about Virginia Roberts? MR. PAGLIUCA: Object to the form and foundation A. I cannot speculate to his views. I can only testify on my views. Q. Earlier you went through the series of lies. Have you talked to Jeffrey about the lies and does he agree with you? A. Ihave discussed some of the issues Filed 01/09/24 Page 77 of 106 DIDO BWNFPWOOANDOAWNE Page 300 G Maxwell - Confidential deny whether he had sex with Virginia Roberts? MR. PAGLIUCA: Objection to the form and foundation. A. Ican't say what Jeffrey would say. Q. Has he discussed that with you? A. He has not. Q. Would Jeffrey be able to confirm or deny whether he had a sexual massage from Virginia that first time she came to his mansion in Palm Beach? MR. PAGLIUCA: Objection to the form and foundation. A. I cannot speak for what he would say. I can only speak for what I would say. So as I testified everything that she said about that first meeting didn't happen so... Q. Has he told that you everything about that first meeting didn't happen? A. I know it didn't happen because she put me in that room. Q. Lunderstand you know. But has Jeffrey said when you are talking about the obvious lies, oh yeah, that never happened? Page 299 G Maxwell - Confidential with him, I can't remember specifically which ones. I just don't recall. I'm sorry. Q. Do you recall him telling you that he didn't agree with you on any of those? A. I don't recall him saying that. Q. Do you have a joint defense agreement with Jeffrey Epstein? A. Ibelieve I do. Q. Do you have a joint defense agreement with Alan Dershowitz? A. Idon't believe I do. Q. Earlier today in your testimony, when I was asking you some questions, you said that you couldn't answer but that Jeffrey Epstein could answer that question. Would Jeffrey Epstein be ina position to confirm or deny some of the obvious lies that we've discussed today? MR. PAGLIUCA: Objection to the form and foundation. A. Ican't possibly testify to what Jeffrey could or would say. I can't speak for him. Q. Would Jeffrey be able to confirm or Page 301 G Maxwell - Confidential MR. PAGLIUCA: Objection to the form and foundation. A. Ican't specifically recall that. I don't know, but he has to agree with me because it didn't happen. Q. Can Jeffrey Epstein, would he be able to confirm or deny whether he had sex with underage girls? MR. PAGLIUCA: Objection to the form and foundation. A. Ican't testify to what Jeffrey would say. Q. Can Jeffrey confirm or deny whether Bill Clinton was on Jeffrey's island? MR. PAGLIUCA: Objection to the form and foundation. A. Ican't say what Jeffrey would say. I can only say what I know to be true. Q. Has Jeffrey talked to you about the fact whether Bill Clinton was on his island? A. As best as I can recollect, he said he was not on the island. As best as I can recollect. Q. Can Jeffrey Epstein confirm whether 6 (Pages 298 to 301) MAGNA® — LEGAL SERVICES