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OMANDNRWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 29 of 134 Page 106 J. Epstein - Confidential Virginia go into the room depicted in the back of the photograph, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And in this photograph, you do see a room depicted in the back? A. Fifth. Q. You're taking the Fifth about what is shown in this photograph? A. I--Ican't see anything. I'm sorry. MR. GOLDBERGER: Okay. So it's -- so we're not -- we're not raising Fifth Amendment privilege. You cannot -- your answer is, you cannot see what Mr. Cassell is referring to? THE WITNESS: Correct. MR. GOLDBERGER: Okay. BY MR. CASSELL: Q. Do you see a window depicted in this photograph? A. I don't know what it is. I'm sorry. Q. Do you see a white light reflecting off of OMNDNRWNK Page 108 J. Epstein - Confidential all the circumstances surrounding this situation to say that you forced Virginia to have sex with Prince Andrew? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What would have happened to Virginia if she had refused to have sex with Prince Andrew? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. At the time Virginia retired to the bedroom with Prince Andrew, Maxwell was in possession and control of Virginia's U.S. pass -- passport, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Who had Virginia's passport when she entered England? MR. PAGLIUCA: Object to form and foundation. Page 107 J. Epstein - Confidential a blue surface in this photograph? A. Yes. Q. Does that appear to you to be a window? A. Not necessarily, no. MR. GOLDBERGER: Why don't you just assume arguendo that -- that that -- what -- what you're trying to have Mr. Epstein identify is a room, and then we can go on from there. MR. CASSELL: All right. BY MR. CASSELL: Q. That room is a bedroom in Ms. Maxwell's flat, true? MR. PAGLIUCA: Object to the form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You and Maxwell instructed Virginia to have sex with Prince Andrew, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, it would be a fair assessment of Page 109 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. After she was inside of English territory, who main con- -- remained in control of her passport? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Virginia was 17 years old at this time, true? A. Fifth. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Sorry. Fifth. BY MR. CASSELL: Q. It was your understanding that Prince Andrew and Virginia was retiring to this bedroom to have sex, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What did you understand Virginia and Prince Andrew to be doing that evening? MAG NA® 28 (Pages 106 to 109) LEGAL SERVICES