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Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 101 of 106 MIDNA HBRWNHRFPDOWOCAIAUYAWNHE Page 394 G Maxwell - Confidential A. Insofar as this is the case, it's really all about Jeffrey, it's not a case about me. Q. In 2009, did you direct your lawyer, either directly or indirectly, to tell Brad Edwards that you were unavailable to attend a deposition? MR. PAGLIUCA: Objection to the form and foundation. And this is a privileged communication as I understand the question, what someone said or didn't say to their lawyer. So don't answer the question. Q. Can you answer that question without revealing a privileged communication? A. Can you ask the question again? Q. In 2009, did you direct your lawyer to tell Brad Edwards that you were unavailable to attend a deposition? MR. PAGLIUCA: Same instruction. Q. Did you make any statement in 2009 to anybody that you were unavailable to attend a deposition? A. My mother was sick and I don't DAIDUBPWNFPOOAIAGTBRWNHE Page 396 G Maxwell - Confidential A. I don't think I've ever discussed it with him. Q. How did you come to learn that Sarah Kellen was covered by the nonprosecution agreement? A. [believe I read it in the press. Q. Did you have any discussions with Sarah Kellen with about the nonprosecution agreement? A. Lhave not had any discussions with Sarah. Q. When is the last time you spoke to Sarah Kellen? A. Maybe 2005, 2006 maybe. Q. And same with Nadia Marcinkova, when is the last time you recall speaking with Nadia Marcinkova? A. Probably even more time before that, maybe -- I've never had communications really with Nadia. Q. I'm sorry, I didn't hear that. A. Inever had communications with her. Q. You were working for Jeffrey at the Page 395 G Maxwell - Confidential recall exactly the sequence of events but what sequence of events do exist are -- was handled by my lawyers. Q. What is your understanding of Jeffrey Epstein's nonprosecution agreement? A. [have no idea. Q. Do you have an understanding of the co-conspirators listed in the nonprosecution agreement? MR. PAGLIUCA: Objection to the form and foundation. A. Ihave no knowledge of his agreement, whatever that is. Q. Do you know, you mentioned earlier today that Sarah Kellen was one of the listed co-conspirators. Do you know who the other co-conspirators are in the nonprosecution agreement? MR. PAGLIUCA: Objection to the form and foundation. A. Ido not know. Q. What did Jeffrey Epstein tell you about the nonprosecution agreement? Page 397 G Maxwell - Confidential same time Nadia was also working for Jeffrey, isn't that correct? A. Ididn't know what Nadia did for Jeffrey so I didn't characterize what her relationship or work or not was and I was still helping him with his construction projects and the like but I never crossed paths with Nadia. Q. What did you think Nadia was doing for Jeffrey? A. Thave no idea what Nadia was doing for Jeffrey. Q. Did you observe Nadia at any of Jeffrey's houses while you were there? A. She was at the house on occasion. Q. What would she be doing there? A. Thave no idea. Q. Did you know if she lived at his houses? A. Thave no idea. Q. Did you ever go into a bedroom and see her belongings at one of the houses? A. Not that I recall, no. Q. I'm going to mark this as Maxwell 00 (Pages 394 to 397) MAGNA® — LEGAL SERVICES