Giuffre_Maxwell_Batch8_p00952.png
Extracted Text (OCR)
OMNDWNWKRWNE
Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 72 of 134
J. Epstein - Confidential
foundation.
THE WITNESS: Sorry.
BY MR. PAGLIUCA:
Q. You would agree with me that you do not
depend on Ghislaine Maxwell for any financial
support, correct?
MR. CASSELL: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. You do not have any business relationship
with Ghislaine Maxwell, correct?
MR. CASSELL: Object to form and
foundation and vague.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. You do not have any social relationship
with Ghislaine Maxwell, correct?
MR. CASSELL: Object to form and
foundation and vague.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Allright. You have not spoken to
Ghislaine Maxwell in many years, correct?
OMNDWNWKRWNE
J. Epstein - Confidential
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Any relationship you had, whether personal
or business, ended with Ms. Maxwell more than
15 years ago, correct?
MR. CASSELL: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Ms. Maxwell is not --
MR. CASSELL: I'm sorry. Could you
mark that question for me as well? The last
one.
BY MR. PAGLIUCA:
Q. Ms. Maxwell is not an employee of yours,
correct?
MR. CASSELL: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Ms. Maxwell is not an agent of yours,
correct?
MR. CASSELL: Object to form and
foundation. Calls for a legal conclusion.
Page 279
J. Epstein - Confidential
MR. CASSELL: Object to form and
foundation, and vague as to what the term
"spoken" means.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. You've not had any verbal communication,
meaning oral, with Ms. Maxwell for many years,
correct?
MR. CASSELL: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. You have not physically seen Ms. Maxwell in
many years, correct?
A. Fifth.
Q. You have not --
MR. CASSELL: I'm sorry. I missed the
-- form and foundation objection.
BY MR. PAGLIUCA:
Q. You have not been in any location
contemporaneously with Ms. Maxwell in many years,
correct?
MR. CASSELL: Object to form and
foundation.
Page 281
J. Epstein - Confidential
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Ms. -- Ms. Maxwell -- you are not an agent
of Ms. Maxwell's, correct?
MR. CASSELL: Object to form and
foundation. Calls for a legal conclusion.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Ms. Maxwell has never authorized you to act
on her behalf, correct?
MR. CASSELL: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Ms. Maxwell does not control any of your
decisions in any way --
MR. CASSELL: Object to form --
BY MR. PAGLIUCA:
Q. -- correct?
MR. CASSELL: Sorry. Object to form
and foundation.
THE WITNESS: Fifth.
BY MR. PAGLIUCA:
Q. Do you understand that Ms. Maxwell opposes
MAGNA® 71 (Pages 278 to 281)
LEGAL SERVICES
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Document Details
| Filename | Giuffre_Maxwell_Batch8_p00952.png |
| File Size | 555.2 KB |
| OCR Confidence | 94.4% |
| Has Readable Text | Yes |
| Text Length | 2,843 characters |
| Indexed | 2026-02-04 12:53:04.096157 |