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OMNDWNWKRWNE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 51 of 134 Page 194 J. Epstein - Confidential BY MR. CASSELL: Q. With regard to the time period referred to in this e-mail, who was your girlfriend? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, during the time when Virginia was with you, Maxwell was your girlfriend, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Who was your girlfriend when Virginia was with you? MR. PAGLIUCA: Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. Did Maxwell respond to this e-mail? A. Fifth. Q. In fact, Maxwell did respond to this e-mail, true? A. Fifth. Q. You and Maxwell decided together that OMNDWNWKRWNE Page 196 J. Epstein - Confidential pseudonym Jane Doe 102, filed a public lawsuit against you for sexual abuse, right? A. Fifth and attorney-client. MR. GOLDBERGER: I'll assert the attorney-client privilege for you. BY MR. CASSELL: Q. It's a matter of public record that you later settled that lawsuit, right? A. Fifth. MR. GOLDBERGER: And attorney-client privilege. And confidentiality of any agreement that may have existed. BY MR. CASSELL: Q. How much money, if any, did you pay to settle that lawsuit? A. Fifth. MR. GOLDBERGER: Attorney-client privilege and confidentiality of any agreement that may or may not have existed. BY MR. CASSELL: Q. That lawsuit involved two parties, you and Ms. Giuffre, right? A. Fifth. Q. _Itis you who is insisting on Page 195 J. Epstein - Confidential trying to pass off Shelly as your girlfriend who be too easily exposed as a lie, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the plan that you and Maxwell came up with to respond to Virginia's allegations that she had been sexually abused by the two of you. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, you two came up with a plan to try to attack Virginia's credibility, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Now, if we go to 2009 -- we're done with that document. - In 2009, Ms. Giuffre, proceeding under the Page 197 J. Epstein - Confidential confidentiality of the settlement of that lawsuit, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client privilege. BY MR. CASSELL: Q. If Virginia were to provide to Maxwell the confidential settlement agreement, that would be, to your personal understanding, a violation of the terms of the settlement agreement? A. Fifth. MR. GOLDBERGER: And attorney-client privilege. BY MR. CASSELL: Q. You could sue Virginia if she gave Maxwell the confidential settlement agreement, right? A. Fifth. MR. GOLDBERGER: Attorney-client privilege. Do you want to give me a standing objection to attorney-client privilege on -- on any of the questions concerning the MAGNA® 50 (Pages 194 to 197) LEGAL SERVICES