Giuffre_Maxwell_Batch8_p00928.png

OMNADNARWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 48 of 134 Page 182 J. Epstein - Confidential was using the term "Virginia" to refer to Virginia Roberts Giuffre, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You see the term "Virginia" on this document? A. Yes. Q. Who do you understand that term to refer to? A. Fifth. Q. Who do you understand this e-mail to have come from? A. Fifth. Q. Who do you understand received this e-mail? A. Fifth. Q. You and Ms. Maxwell were working together to try defend the civil lawsuit that Virginia had filed against you, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Sorry. Say it gain. OMANDWNWRWNE Page 184 J. Epstein - Confidential attorney-client privilege to the extent Mr. Epstein's knowledge of the lawsuit or the date of the lawsuit emanates from the attorney-client communication. MR. GOLDBERGER: Did you not get that? THE COURT REPORTER: No. MR. GOLDBERGER: I'll -- I'll rephrase it. In addition to the Fifth Amendment privilege, we are invoking attorney-client privilege to the extent that any knowledge that Mr. Epstein has about a lawsuit filed against him by someone by the name of Virginia Roberts came to him from attorneys. BY MR. CASSELL: Q. Did you respond to this e-mail, sir? A. Fifth. Q. It's true, sir, that you responded to this e-mail, right? A. Fifth. Q. And your response was along the lines of coordinating with Maxwell as to how best to defend the lawsuit against you? MR. PAGLIUCA: Object to form and Page 183 J. Epstein - Confidential BY MR. CASSELL: Q. You and Miss Maxwell were working together to try to defend the civil lawsuit that Virginia filed against you at this time, true? MR. PAGLIUCA: Object to form and foundation. MR. GOLDBERGER: Against Mr. Epstein, not against Ms. Maxwell? MR. CASSELL: Correct. MR. GOLDBERGER: Thank you. THE WITNESS: Sorry. Okay. MR. CASSELL: Let me just ask -- MR. GOLDBERGER: Okay. BY MR. CASSELL: Q. It's true, sir, that in July of 2009, Virginia had a lawsuit pending against you, right? A. Fifth. MR. CASSELL: And you're taking the Fifth with regard to a publicly-filed lawsuit, I understand it; is that right? MR. GOLDBERGER: That's correct. BY MR. CASSELL: Q. Did you respond to this e-mail? MR. WEINBERG: I will also assert the Page 185 J. Epstein - Confidential foundation. THE WITNESS: Fifth. (Plaintiff's Exhibit JE6, E-mail string between Jeffrey Epstein and Ms. Maxwell on about March 25th, 2011 was marked for identification.) BY MR. CASSELL: Q. Allright. Let's go to another document, which I'll mark as JE6. Do you see JE6 in front of you? A. Yes. Q. This is an e-mail string between you and Ms. Maxwell on about March 25th, 2011, right? MR. GOLDBERGER: There appears to be one e-mail only. Do you have the right exhibit? MR. CASSELL: Oh, I'm sorry. No -- are we looking at the same thing? I see one e-mail and then a second one. MR. GOLDBERGER: I'm sorry. BY MR. CASSELL: Q. This appears to be a -- an e-mail from Maxwell to you, followed by an e-mail from you to Maxwell, correct? MAGNA® 47 (Pages 182 to 185) LEGAL SERVICES