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OMNDWNWKRWNE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 6 of 134 Page 14 J. Epstein - Confidential Mr. Epstein, for instance, a response to whether he even recognizes the name of your client, in the event you choose to challenge the essential applicability of the long-standing Fifth Amendment privilege. MR. CASSELL: I'm going to object to Mr. Weinberg defending the deposition in addition to Mr. Goldberg. My understanding of the rules -- MR. GOLDBERGER: Goldberger. It's Goldberger. MR. CASSELL: I'm sorry. I apologize. Mr. Goldberger. It seems to me, the standard is one lawyer for one witness. And Mr. Goldberger is a very capable lawyer, so it seems to me Mr. Weinberg should not be allowed to participate by making objections. MR. PAGLIUCA: And for the record, I have no objection to Mr. Epstein simply saying, Fifth Amendment in response to any questions and understand that that answer would incorporate all of the first answer that Mr. Epstein gave in this deposition. OMNDWNWKRWNE J. Epstein - Confidential to be a citizen of? A. Fifth. Q. You understand that the case caption on the subpoena you received is Virginia Giuffre versus Ghislaine Maxwell? A. Fifth. Q. You know the Defendant in this case, Ghislaine Maxwell, true? A. Fifth. Q. You first met Maxwell in the early 1990s; isn't that true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. CASSELL: Let me make sure I understand. What's the objection to form? MR. PAGLIUCA: The question is vague. BY MR. CASSELL: When did you first meet Ms. Maxwell? Fifth. Where did you first meet Ms. Maxwell? Fifth. What were the circumstances surrounding Page 15 J. Epstein - Confidential MR. GOLDBERGER: Thank you. BY MR. CASSELL: Q. Sir, you've been deposed many times before, true? A. Fifth. Q. You understand the rules regarding the deposition today, true? A. Fifth. Q. You have legal counsel here today to provide advice to you, should it be necessary at any point, true? A. True. Q. Is there anything, including any physical conditions or ailments, that would prevent you from giving truthful testimony today? A. Fifth. Q. Please state your full name. A. Jeffrey Edward Epstein. Q. Without disclosing where you may have lived in the past, where do you currently reside? A. Fifth. Q. What state are you a citizen of? A. Can you clarify the question? Q. Yeah. What state do you consider yourself MAGNA® Page 17 J. Epstein - Confidential your first meeting of Maxwell? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Could you repeat the question? BY MR. CASSELL: Q. What were the circumstances surrounding your first meeting of Maxwell? MR. PAGLIUCA: Same objection. THE WITNESS: Fifth. MR. CASSELL: And when you say "form," you believe that the question that I just asked is vague? MR. PAGLIUCA: It is vague. I don't understand what "circumstances" means. It lacks foundation, in that there hasn't been an establishment of any time or place of meeting of Ms. Maxwell or even that he knows Ms. Maxwell under the circumstances of this deposition. MR. CASSELL: Right. But you understand there is evidence in the record from which I would have a good faith basis for believing that he has, in fact, met 5 (Pages 14 to 17) LEGAL SERVICES