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OMANDWNWRWNE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 66 of 134 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, you arranged for Alfredo Rodriguez to be threatened by Maxwell, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2009, your attorneys attended a deposition of Alfredo Rodriguez, right? A. Fifth. Q. At that time, it was in your interest to limit the ways in which Rodriguez could expose the sex abuse of both you and Maxwell, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. When Rodriguez was describing Maxwell's involvement with underage girls, your attorneys had an interest in attacking that testimony, right? MR. PAGLIUCA: Object to form and foundation. MR. WEINBERG: Attorney-client OMANDWNWRWNE Page 256 J. Epstein - Confidential MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Allegations Virginia made had never been shown to be untrue, had they? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. I'll represent to you that Ms. Maxwell released a statement that said, "Each time the story is retold it changes with new salacious details about public figures and world leaders." And then there's some additional language. You had, in fact, sexually trafficked Virginia to public figures? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, you had trafficked Virginia to world leaders, right? MR. PAGLIUCA: Object to form and Page 255 J. Epstein - Confidential privilege. THE WITNESS: Fifth. MR. WEINBERG: If the information came from attorneys. MR. CASSELL: Could we take a short break at this time? VIDEO TECHNICIAN: Off the record at 11:35. (A recess was taken.) VIDEO TECHNICIAN: Beginning of disc three. On the record at 11:50. BY MR. CASSELL: Q. Sir, I want to represent to you that on about January 2nd, 2015, Defendant Maxwell released a statement that said, "The allegations made by Virginia Roberts against Ghislaine Maxwell are untrue." That was a false statement, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, the allegations made by Virginia Roberts against Ghislaine Maxwell were true? Page 257 J. Epstein - Confidential foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And Maxwell had assisted you in trafficking Virginia to public figures and world leaders? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the public figures you and Maxwell and Virginia interacted with. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the world leaders you and Virginia and Maxwell interacted with. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Irepresent to you that around January 2nd, 2015, Ms. Maxwell released this statement that "Ms. Roberts’ claims are obvious lies and should be MAG NA® 65 (Pages 254 to 257) LEGAL SERVICES