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OMANDNRWNKE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 64 of 134 J. Epstein - Confidential BY MR. CASSELL: Q. Please list any lies that, sitting here today, you're aware of that Virginia has ever told. A. Fifth. Q. You're unwilling to identify any lies that Virginia has ever told, right? A. Fifth. Q. In fact, you are unable to list any significant lies that Virginia has ever told? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Without regard to any sexual abuse that you may or may not have committed in the past, do you agree that it is psychologically harmful for an adult male to have sex with a minor female? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What sort of psychological impact do you think it would have for a 40-year-old man to have sex with a 17-year-old girl? OMANDWNWRWNE Page 248 J. Epstein - Confidential BY MR. CASSELL: Q. You know Virginia Roberts, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Based on your interactions with Virginia Roberts, what sort of psychological impact do you think it had when she was called a liar by Maxwell? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. It would have a significant psychological harm on Virginia Roberts for Maxwell to call her a liar about true statements, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please tell me everything you know about Nadia Marcinkova. A._ Fifth. Page 247 J. Epstein - Confidential MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What kind of psychological impact do you think it would have for a 40-year-old -- a man in his 40s to have sex with a 16-year-old girl? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You would agree that calling someone a liar when they're telling the truth can cause psychological harm, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What kind of impact would calling someone a liar when they are actually telling the truth? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. Page 249 J. Epstein - Confidential Q. Please tell me everything you know about Sarah Kellen. A. Fifth. Q. Both you and Maxwell have had sex with Nadia Marcinkova, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Both you and Maxwell have had sex with Sarah Kellen? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the role that Sarah Kellen played in your sex trafficking organization. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What did Sarah Kellen do for you in 2005? MR. PAGLIUCA: Object to form and MAG NA® 63 (Pages 246 to 249) LEGAL SERVICES