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Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWODIA UY AWNHE Page 358 G Maxwell - Confidential last question. MS. McCAWLEY: I'm not withdrawing anything. I'm asking a question. MR. PAGLIUCA: There was a question pending. You didn't let the witness answer the question, then you moved on to another question so I'm asking for clarification for the record now which question are we answering. MS. McCAWLEY: There is an answer. The question was did he tell you anything, there was anything in the statement inaccurate about the statement and she said again, I read the whole thing -- THE WITNESS: I would have to. MS. McCAWLELY: -- I would have to read the whole thing to figure that out. MR. PAGLIUCA: Then she started reading it and you asked another question. MS. McCAWLEY: That's the question. MR. PAGLIUCA: I'm wondering if its still pending. Filed 01/09/24 Page 92 of 106 DIDO BWNFPWOOANDOAWNE Page 360 G Maxwell - Confidential MR. PAGLIUCA: Objection to the form and foundation. A. I was not coordinating with Jeffrey. He had details that I did not have. I was not party to his case. I needed to have information in order to be able to respond so I was not coordinating with him. I was merely asking for details that I could have. Q. Did Jeffrey write any of your press statements for you? A. No. Q. He didn't draft any of them? A. Ihave a lawyer who was working on this and that was -- I asked, I believe as I recollect asked him for information to make sure I was being accurate in the representations for whatever I was discussing. Q. Did Jeffrey provide you with any drafts of statements to provide to the press? A. lonly recall drafts from my lawyer. Q._ I will mark this as Maxwell 17. Page 359 G Maxwell - Confidential MS. McCAWLEY: It was answered. Q. Were you coordinating with Jeffrey Epstein during the time period in 2011 regarding the statements you were issuing to the press? MR. PAGLIUCA: Objection to the form and foundation. A. Lonly wanted to be accurate in any factual statements that I made. Q. You knew at that time that Jeffrey Epstein had been convicted for sexual abuse of a minor, is that correct? MR. PAGLIUCA: Objection to form and foundation. A. He was sentenced I believe for underage -- soliciting an underaged prostitute. Q. You knew that he was a registered sex offender? A. Yes. Q. You were coordinating with him the statement that you were going to be making to the press to confirm whether they were accurate in your words? Page 361 G Maxwell - Confidential (Maxwell Exhibit 17, email, marked for identification.) Q. This is an email from you on January 10, 2015 to Philip Barden and Ross Gow. The statement you had before you earlier, that, if you can pull that in front of you, the one page press release that you gave. You might know from memory. Was the press release that you issued with the statement about Virginia issued in or around January 2, 2015? A. As best as I can recollect. Q. I want to turn your attention to the document I just handed you which is Bates No. 001044, from you to Philip Barden and Ross Gow. It says in the first sentence, I'm out of my depth to understand defamation, other legal hazards and I don't want to end up in a lawsuit aimed at me from anyone, if I can help it. Apparently, even saying Virginia is a liar has hazards. You knew at the time you called Virginia a liar in early January of 2015 that that was something that would result in a 91 (Pages 358 to 361) MAGNA® LEGAL SERVICES