Giuffre_Maxwell_Batch8_p00896.png
Extracted Text (OCR)
Neeee eee eee
SCOMADNEWNRFOUOMANAUNAPWNHE
Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 16 of 134
Page 54
J. Epstein - Confidential
process of the proceeding. Fair?
MR. CASSELL: You would be preserving,
obviously, a form objection and a foundation
objection.
MR. PAGLIUCA: Sure. I guess the
questions then becomes what does that mean.
MR. CASSELL: Right.
MR. PAGLIUCA: So I can keep objecting,
as I am, or we can have some agreement. But
why don't we keep going and we'll see what
happens.
MR. CASSELL: Right. And I -- it would
be my position that anything beyond form and
foundation should be stricken.
MR. PAGLIUCA: Okay.
MR. CASSELL: Unless you can -- and
that's -- that's the way to proceed.
(Plaintiff's Exhibit JE1, Transcript of the
deposition of Ms. Maxwell taken on April 22nd, 2016
was marked for identification.)
BY MR. CASSELL:
Q. Allright. Sir, I want to hand you a
document, which I'm document I'm going to mark as JE1
for Jeffrey Epstein 1. And I'll represent and
OMNDWNWKRWNE
J. Epstein - Confidential
Ms. Maxwell.
Do you see that answer?
A. Yes.
Q. The answer is, "I think you should ask that
question of Jeffrey."
Do you see that answer?
A. Yes.
Q. So following up on Ms. Maxwell's
suggestion, I'm going to ask you the same question.
Was it your preference to start a massage
with sex?
A. Fifth.
Q. Itis true that your preference was to
start a massage with sex?
MR. PAGLIUCA: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. CASSELL:
Q. I don't know that I completely finished the
question. So let me just re-ask it.
It is true that your preference was to
start a massage with sex, correct?
MR. PAGLIUCA: Objection to form and
foundation.
Page 55
J. Epstein - Confidential
provided a copy to both Mr. Goldberger and
Mr. Pagliuca. I represent that this is a transcript
of the deposition of Ms. Maxwell taken on April 22nd,
2016.
You have that document in front of you,
sir?
A. Yes.
Q. If could ask you to flip to page 100.
And since there are two sets of numbers, this would
be the smaller set of numbers up on the, for example,
the top of the page. These -- these are four pages
per page. And page 100. I'd like to direct your
attention to page 100, line 8. Actually, I'm sorry,
page 100, line 10.
Do you see where I am, sir?
A. Yes.
Q. On line 10 there is a question: "Did
Jeffrey -- was it Jeffrey's preference to start a
massage with sex?"
Do you see that question, sir?
A. Yes.
Q. And then if we skip over two lines where
there's a form and foundation objection, we go to
line 14 where there is an answer given by
MAGNA®
OMANDMNPWNH
a
fo)
Page 57
J. Epstein - Confidential
THE WITNESS: Fifth.
BY MR. CASSELL:
Q. To your knowledge, when she was deposed on
April 22nd, 2016, Maxwell knew that your preference
was to start a massage with sex, true?
MR. PAGLIUCA: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. CASSELL:
Q. Itis true that you directed Maxwell to
recruit girls under the age of 18 who would have sex
with you all under the guise of providing a massage,
correct?
MR. PAGLIUCA: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. CASSELL:
Q. One of the girls under the age of 18 with
whom you had massages starting with sex was Virginia,
true?
MR. PAGLIUCA: Object to form and
foundation.
THE WITNESS: Fifth.
15 (Pages 54 to 57)
LEGAL SERVICES
Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch8_p00896.png |
| File Size | 586.3 KB |
| OCR Confidence | 93.6% |
| Has Readable Text | Yes |
| Text Length | 3,345 characters |
| Indexed | 2026-02-04 12:52:41.609474 |