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Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 103 of 106 DIDO BWNFPWOOANDOAWNE Page 402 G Maxwell - Confidential form and foundation. A. I've never seen Andrew interact in any way of that nature. Q. Have you ever gone to dinner with him with any individual under the age of 18 that's not a family member or friend of yours that is under the age of 18? MR. PAGLIUCA: Objection to form and foundation. A. We've been to dinner all the time, Iam not not sure who is at dinner with us, I can't testify to that. Q. Has he ever brought a female under the age 18 that's not a relative of his -- A. He has children. Q. Isaid not relatives. A. I can't possibly testify to who he comes to dinner with, I wouldn't recall. Q. To your knowledge, has he ever had a relationship with any female under the age of 18 for purposes of a romantic relationship to your knowledge? A. I can't testify to Andrew's relationship. DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE Page 404 G Maxwell - Confidential form and foundation. A. Imean I've been to his -- in the mid '90s, I would have communicated with people who worked for him. Q. Have you communicated with Leslie Wexner about this case? A. No. Q. Have you ever seen a topless female at any one of Jeffrey Epstein's properties? MR. PAGLIUCA: Objection to the form and foundation. You've asked this question, by the way, earlier on today. A. Again, I testified that there are people who from time to time in the privacy of a swimming pool have maybe taken a bikini top off or something but it's not common and certainly when I was at the house I don't really recollect seeing that kind of activity. Q. Have you ever smoked cigarettes? A. Yes. Q. Have you ever smoked cigarettes with Virginia Roberts? A. I don't recall smoking cigarettes Page 403 G Maxwell - Confidential Q. You haven't observed that? A. No. Q. Have you talked to Prince Andrew about coming to testify at trial in this case? A. No. Q. When was the last time you communicated with Leslie Wexner? A. 1994, 1995. Q. Ibelieve earlier, did you say that you -- when is the last time you've been to his home in Ohio? A. Isaid -- you asked me if I stayed the night. Q. I'm asking you a different question. When is the last time you have been to his home in Ohio? A. Roughly the same time, in the middle of the '90s sometime, mid '90s. Q. Not in the years 2000 to 2002? A. Mid '90s. Q. Have you ever communicated with any representative of Leslie Wexner? MR. PAGLIUCA: Objection to the Page 405 G Maxwell - Confidential with Virginia Roberts. Q. I'm marking this as Maxwell 25. (Maxwell Exhibit 25, email, marked for identification.) Q. I'm showing you what has been marked as Maxwell 25. This is an email dated January 11, 2015 at the top? Do you see that that from Jeffrey to you? A. Uh-huh. Q. And then below there is an email from Philip Barden to you and cc'ing Ross Gow on January 11, 2015. Do you see that? A. Uh-huh. Q. Itsays, Dear Ghislaine, as you know I have been working behind the scenes and this article comes from that. It helps but doesn't answer the VR claims. I will get the criminal allegations out. This shows the MOS will print truth, not just a VR voice piece. We can only make the truth by making a statement. 02 (Pages 402 to 405) MAGNA® — LEGAL SERVICES