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OMNDWNWKRWNE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 19 of 134 Page 66 J. Epstein - Confidential well, don't you? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Virginia has told the truth about you using Maxwell to recruit girls for you to sexually abuse, true, sir? MR. PAGLIUCA: Objection to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please give us all the information that you have regarding how credible Virginia is. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please give us all information you have about Virginia's credibility on issues relating to sex abuse. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. COMIDNEWNH Page 68 J. Epstein - Confidential about threesomes between you, Maxwell, and her would be the three of you, correct? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And when I refer -- refer to "a threesome" in today's deposition, will you understand that I'm referring to sexual activity among three people occurring essentially simultaneously? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What is your understanding of the term "threesome"? A. Fifth. Q. Without regard to any conduct that you may or not have undertaken in the past, what do you understand the word "threesome" to mean? A. Fifth. Q. Let's now go to page 197 of the transcript. Oh, I'm sorry. Actually, let's go to the very bottom of page 196. Page 67 J. Epstein - Confidential BY MR. CASSELL: Q. Please give us all information you have showing that Virginia is credible about allegations she's made against you. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please give us all the information you have about how Virginia is credible with regard to her allegations against Maxwell. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Is there anybody else that I could check with besides you to follow up on Ms. Maxwell's suggestion of obtaining information about Virginia's credibility with regard to sexual abuse by you? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q._ Sir, it's true that the only one who knows MAGNA® OMNDNRWNE Page 69 J. Epstein - Confidential Do you see line 25 on page 196? A. Yes. Q. And the question is: "That's all he said about Virginia?" Do you see that question? A. I don't see a question mark, do you? Q. On line 2 of page 197? A. Yes. Q. And so this is a reference back to line 24 on page 196. Do you see line 24 on page 196? A. Yes. Q. And the answer there from Maxwell is, "All he" -- that is Epstein in context -- "told me that she is a liar." Do you see that answer? Do you see the answer there on line 24? A. Yes. Q. That is not accurate testimony, is it, sir? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, you told Ms. Maxwell that you were concerned that people would learn the truth 18 (Pages 66 to 69) LEGAL SERVICES