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OMANDNRWNKE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 69 of 134 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe all the situations in which you and Maxwell have been involved in the interstate transportation of girls under the age of 18. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You have used cell phones and land line cell phone -- land line telephones to instruct Virginia Roberts to have sex, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You've given instructions by telephone to Virginia Roberts to have sex with people while she is under the age of -- while she was under the age of 18, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. OMANDNRWNKE J. Epstein - Confidential foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, you have threatened witnesses not to talk, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, Ghislaine Maxwell has threatened witnesses not to talk, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In about 2007, you arranged to have someone hunt down and find Virginia, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. How did you find Virginia in 2007? MR. PAGLIUCA: Object to form and foundation. Page 267 J. Epstein - Confidential BY MR. CASSELL: Q. You have instructed girls under the age of 18 via telephone and cell phone to have sex with men, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You've instructed girls under the age of 18 by telephone to have sex with various of your friends, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Have you ever threatened a witness not to talk? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Has Ghislaine Maxwell ever threatened a witness not to talk? MR. PAGLIUCA: Object to form and Page 269 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason you needed to find Virginia in 2007 was because the FBI had opened an investigation on you, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. When was the last time you spoke to Ms. Giuffre? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Who? BY MR. CASSELL: Q. Miss Virginia Roberts -- A. Sorry. Sorry. Q. -- Giuffre. Yeah. Virginia, I should say. Yeah. A. Fifth. Q. When was the last time you spoke to Virginia? A. Fifth. Q. In fact, you and your attorney actually got MAG NA® 68 (Pages 266 to 269) LEGAL SERVICES