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Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 100 of 106 DIDO BWNFPWOOANDOAWNE Page 390 G Maxwell - Confidential MR. PAGLIUCA: Object to the form and foundation. A. Ifyou want to ask Jeffrey questions about me, you would have to ask him. Q. Have you ever been involved in any illegal activity in your lifetime? MR. PAGLIUCA: Objection to the form and foundation. A. I can't think of anything I have done that is illegal. Q. Have you ever been arrested? A. Ihave a DUI in the U.K. a long time ago. Q. Is that the only arrest you have on your record? A. Yes. Q. Iwill mark as Maxwell 22 this email? (Maxwell Exhibit 22, email, marked for identification.) Q. This is dated January 21, 2015. It's from Jeffrey Epstein to you, forwarding the Guardian and I would like you to look at DMIADGTUBWNHRFROOAIA oBWNHE Page 392 G Maxwell - Confidential This will now end? MR. PAGLIUCA: Objection to the form and foundation. A. Thave no idea. Q. Did you discuss with him what he meant by the statement, This will now end? A. I don't recall. Q. Was he taking any action to ensure that, quote, this will now end? A. Thave no idea. (Maxwell Exhibit 23, email, marked for identification.) Q. This is an email from, if you look at the chain at the top, you will see it's from you to Jeffrey on January 27 and the email at the bottom of the chain is from Jeffrey to you on January 27. He states, What happened to you and your statement, question mark, question mark. And you put at the top, I have not decided what to do. A. Uh-huh. Q. Why was Jeffrey interested in you making a statement to the press? Page 391 G Maxwell - Confidential the chain of emails so you understand the -- have an appreciation for who is on this. It's a three-page document. The bottom of the email appears to be a message from, there is a -- at the very bottom there is the signature block for Ross Gow, who I understand is your press agent and above that there is a message from a John Swaine to Ross Gow. Do you see that? A. Uh-huh. Q. Do you know who John Swaine is? A. Ido not. Q. Above that there is a message from Ross Gow to Philip Barden and you and it says, so this isn't getting better, latest from our chums at the Guardian and above that you will see on January 21 an email from you where you wrote, See below. And right above that chain you will see Jeffrey Epstein to you on January 21 and his statement to you is, This will now end but I think a dismissive statement is okay. What did he mean by his statement, MAGNA® Page 393 G Maxwell - Confidential MR. PAGLIUCA: Objection to the form and foundation. A. I don't know that he was interested. We made a statement and then I was being advised to make an additional statement and I never did. Q. Was Jeffrey communicating with you regularly on what additional statement you might make? MR. PAGLIUCA: Objection to the form and foundation. A. No, I've communicated with him very little, as little as possible. Q. Why did you feel you had to keep him informed of statements you were making to the press? MR. PAGLIUCA: Objection to the form and foundation. A. I didn't feel I had to. Q. Then why you were communicating with him about statements you were making to the press? MR. PAGLIUCA: Objection to the form and foundation. 99 (Pages 390 to 393) LEGAL SERVICES