Giuffre_Maxwell_Batch8_p00890.png

Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 10 of 134 Page 30 Page 32 J. Epstein - Confidential MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe how the solicitation to which you pled guilty was accomplished. MR. PAGLIUCA: Object to form and BY MR. CASSELL: foundation. Q. What was your understanding of the legal THE WITNESS: Fifth. crime to which you were pleading guilty? MR. CASSELL: Can you tell me what the form MR. PAGLIUCA: Object to form and objection was to that? foundation. MR. PAGLIUCA: Please tell me how the THE WITNESS: Fifth. solicitation was accomplished? BY MR. CASSELL: MR. CASSELL: Yes. Q. What was your understanding of what you MR. PAGLIUCA: Okay. Well, you're were admitting in open court that day? asking for a legal definition from this lay MR. PAGLIUCA: Object to form and witness as to solicitation, how it was foundation. accomplished. I don't know what that means. THE WITNESS: Fifth. Your question is vague, it's ambiguous, it BY MR. CASSELL: calls for a legal conclusion. It's also Q. Now, with regard to the two crimes that you lacking in foundation. pled guilty, where did those two crimes take place? MR. CASSELL: Because? A. Fifth. MR. PAGLIUCA: Well, as I understand Q. And I suppose there could be a form it, your position is that he pled guilty to objection to that question being compound. So to Page 31 Page 33 J. Epstein - Confidential BY MR. CASSELL: Q. What did you do that led you to plead guilty? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. OMANDWNWRWNE Re Re eR RR RH OMADNARWNKFOTOOMINIAUNUARWNH N pan J. Epstein - Confidential J. Epstein - Confidential made-up crimes that didn't have a factual obviate any issue, I'm going to ask you, was one of basis and this was a conspiracy between the victims in that case a girl who was 14 years old Mr. Epstein and the U.S. Attorney's Office who we could identify by initials $.G.? to avoid prosecution for federal criminal MR. PAGLIUCA: Object to form and charges, which is the basis for your foundation. challenge to -- in the CVRA litigation, as I THE WITNESS: Fifth. understand your pleadings. So I'm not MR. CASSELL: And Mr. Goldberger, is -- if exactly sure how you can actually have a we refer to the victim in -- I believe it was good faith basis for asking that question, Count | or at least one of the accounts by S.G. given your position in writing. Is that an acceptable way to proceed rather MR. CASSELL: All right. You've than putting her name into the record, or could mischaracterized our position. And I I write her name out and provide that to you and imagine we'll have to discuss that later. your client? What would you -- I want to avoid MR. PAGLIUCA: Sure. putting the names of 14-year-old sex victims MR. CASSELL: Since there were into the transcript here. objections to form, let me just try to ask a MR. GOLDBERGER: It's your deposition. series of questions, then, to avoid the form MR. CASSELL: All right. So what I'm objection. going -- BY MR. CASSELL: 20 BY MR. CASSELL: Q. How did you accomplish the crime that you Q. Sir, you understand when I use the term pled guilty to? 22 "S.G." who I'm referring to, true? MR. PAGLIUCA: Object to form and 23 MR. PAGLIUCA: Object to form and foundation. 24 foundation. THE WITNESS: Fifth. 25 THE WITNESS: Fifth. MAGNA® 9 (Pages 30 to 33) LEGAL SERVICES