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Case 1:15-cv-07433-LAP Document 1335-4 AIANDUBPWNHrRPOW ADA ATDUOBWNEH Page 282 G Maxwell - Confidential what she -- MR. PAGLIUCA: She is asking you a different question. She is asking other than what your lawyers have told you, do you have any knowledge about her being 17, that's what she is asking. A. Ican't recollect where I got all the information that I have that definitively shows that. Q. Earlier in your testimony, I believe you said all of us would know that Virginia was 17 at the time you met her. How would we know that? A. I think you know that by her own dates, now that it was in 2000, so her entire tail of me celebrating her 16th birthday is clearly another giant falsehood. Q. But she was 16 and 17 that year, wasn't she? A. Which year? Q. You said it was 2000. A. I think the information that I have that indicates that definitively was something that is privileged, so I can't Filed 01/09/24 Page 73 of 106 DIDO BWNFPWOOANDOAWNE Page 284 G Maxwell - Confidential calls for a communication that you had with one of your lawyers, I'm instructing you not to answer that question. Q. Lassume you, as part of the discovery process, had to collect documents that were relevant to this action, is that correct? A. Idid. Q. Did you collect documents that would show that Virginia was 17 at the time that you met her? A. I think you have everything that relates, that I had, contemporaneously per what you asked for that I have that relates to that. Q. Did you have a document that identified that Virginia was 17 at the time that you met her? A. You have all of the documents that Thad. Q. I'm not asking what documents. I'm asking, do you have a document that identifies Virginia being 17 at the time you Page 283 G Maxwell - Confidential share with you. Q. So you have privileged information that definitively tells you that she was 17 at the time you met her? A. Ibelieve I do. Q. How would we know that? A. What are you asking me? Q. Earlier today you testified that we would know that she was 17 at the time that you met her. How would we know that? A. Limagine you have access to exactly the same information that I do. Q. What is that information? A. Again, it's privileged, I can't share it with you but you have been on this case for, I don't know, much much longer than I have and I imagine you have all the information that I do. Q. Do you know whether your lawyers have produced documents from you that would show the age that Virginia was at the time that you met her? MR. PAGLIUCA: To the extent that MAGNA® Page 285 G Maxwell - Confidential met her? A. You have every document that I have. You have seen every document that I have. Q. That's not what I'm asking. A. I don't recall every document that I gave you, so I don't know. I would have to look at every single document I gave you and then review it but as I recall you have every document that I have. Q. What are you planning to show the jury that will prove that Virginia was 17 when you met her? A. Again that's privileged so I can't share that with you. Q. Ifyou're showing the jury, it wouldn't be privileged, so is there a document you have produced in this matter that shows that Virginia was 17 at the time you met her? MR. PAGLIUCA: She answered that question already. She said she doesn't know, she has given you everything. If there is a decision -- assuming for the 72 (Pages 282 to 285) LEGAL SERVICES