Giuffre_Maxwell_Batch8_p00851.png

Case 1:15-cv-07433-LAP Document 1335-4 DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE Page 346 G Maxwell - Confidential Q. Ifyou go down further, you're going to see halfway through the page, you will see your email address the and you will see a statement that says, Thank you. I have it now. I'm working on the letter a little. I will send final version tomorrow and whatever is in it will be factually accurate. Beneath that you will see Philip Barden who I believe you identified earlier as one of your attorneys? A. Uh-huh. Q. And you will see a letter, starting the text of a letter starting, I want you to turn to the second page which is GM 00110. About halfway through the page, it says you will also presumably draw attention to the fact that prior to filing her suit against Mr. Epstein, Ms. Roberts fled the U.S. to avoid being arrested for grand theft. Police report available. What grand theft were you referring to there that Virginia Roberts committed? MR. PAGLIUCA: Objection to the Filed 01/09/24 Page 89 of 106 AINDTHBWNHROWOANIDA YAWNHE NNNNN NY OBWNR OY Page 348 G Maxwell - Confidential A. I don't know who has this document. Q. What's your basis in that statement for saying Ms. Roberts fled the U.S.? A. Again, you are asking me for a statement that I made in 2011 and I can't say what in 2011 exactly the basis of that statement was. Q. So you don't know whether or not that statement is true? A. This is in 2011 and it never went out, so I'm not sure exactly. Q. But you said in your email that you were working to make it factually accurate, is that correct? A. That's what it says. Q. I'm going to mark as Maxwell 15 a document dated February 24, 2015? (Maxwell Exhibit 15, email, marked for identification.) Q. This is an email from Ross Gow who you've identified as your press agent on February 24, 2015 to which | understand to be your email address and Philip Barden. The subject line says, VR cried rape. Prior Page 347 G Maxwell - Confidential form and foundation. A. I don't know. However, I believe she stole money from somewhere where she worked. Q. How do you know that was grand theft? A. I don't know how I know that. Q. So you authorized a statement that characterized that as grand theft without knowing whether it was grand theft? A. What month, what is the date of this? Q. The date of this is June 12, 2011? A. So I'm afraid such a long time ago, I'm not sure how, I really couldn't testify as to how that language ended up in here. Q. Do you have the police report? It says police report available. Do you have that document? A. I don't have that document. Q. Who does? A. Lhave no idea. Q. Would your lawyer Philip Barden have that document? MAGNA® DAIANDUBWNHRFPOWODAIDUBWNHE Page 349 G Maxwell - Confidential case dismissed as prosecutors found her not credible. The message says, Ghislaine, some helpful leakage, dot dot dot. What is it you were leaking to the press? MR. PAGLIUCA: Objection, there is no foundation that she leaked anything and you know that. Q. What was it that you were leaking to the press in that statement? A. Again, I don't think that's referring to that, that's just referring to the press getting hold of whatever story it is. Q. What was Ross Gow leaking to the press? MR. PAGLIUCA: Objection to form and foundation. A. It doesn't say Ross was leaking anything. It doesn't say that. Q. The statement says, helpful leakage, is that correct? A. It says helpful leakage. That doesn't mean he leaked anything. Q. Did you leak to the 88 (Pages 346 to 349) LEGAL SERVICES