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OMANDNRWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 25 of 134 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. It would be a fair statement to describe Virginia's situation from the fall of 2000 through July 2001 as your sex slave, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You understand the term "sex slave," don't you, sir? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Without to regard to any conduct that you may or may not have committed, what does the term "sex slave" mean to you? A. Fifth. (Plaintiff's Exhibit JE2, Document with titles of books was marked for identification.) BY MR. CASSELL: Q. I'm going to show you what I'll mark as JE2. OMANDNRWNK Page 92 J. Epstein - Confidential true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You relied on the Defendant in this case, Ghislaine Maxwell, to keep Virginia available for to you sexually abuse, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Are we finished with this? BY MR. CASSELL: Q. Yes. MR. CASSELL: Did we get an answer to -- to that? MR. PAGLIUCA: Yes, you did. We did not? MR. GOLDBERGER: Yes. I thought he said the Fifth. BY MR. CASSELL: Q. Let me just re-ask the question, because it's an important one. Sir, you relayed on the Defendant in this Page 91 J. Epstein - Confidential A. Are you finished with this? Q. Yeah. We're through with that now. You recognize the books listed on this document, don't you, sir? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The first book listed here as being sold by Amazon is "Slave Craft: Road Maps For Erotic Servitude, Principles, Skills, and Tools." Do you see that, sir? A. Yes. Q. That was a book you ordered, sir, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The second book listed here is "Training With Ms. Abernathy. A Workbook For Erotic Slaves and Their Owners." Do you see that there, sir? A. Yes. Q. That was another book that you ordered, MAGNA® Page 9 J. Epstein - Confidential case, Ms. Maxwell, to keep Virginia available -- available for you to sexually abuse, true? MR. PAGLIUCA: Objection to the form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What did Miss Maxwell do for you in the years 2001 and 2001? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please briefly describe the nature of the interactions you observed between the Defendant in this case, Ms. Maxwell, and the Plaintiff in this case, Ms. Virginia Roberts, from -- Miss Virginia Roberts Giuffre, from the fall of 2000 through the summer of 2001. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason you're taking the Fifth, with regard to Maxwell's interactions, is that she was 24 (Pages 90 to 93) LEGAL SERVICES