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OMNADNARWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 75 of 134 Page 290 J. Epstein - Confidential Ms. Maxwell were false, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Can you tell me, Mr. Epstein, given that the allegations against you in the complaint by Ms. Roberts/Giuffre were false, why did you settle the lawsuit? MR. CASSELL: Form. Foundation. MR. GOLDBERGER: And attorney-client privilege. MR. WEINBERG: Attorney-client privilege. Sorry, Jack. MR. GOLDBERGER: That's okay, Marty. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And without regard -- so I'm not asking you for any communication between you and any lawyer. Given the fact that the allegations given by Miss Giuffre/Roberts against you were false, without discussing any information communicated to you by any lawyer, what were your personal reasons for settling the lawsuit? MR. CASSELL: Form. Foundation. COMIDNEWNH Page 292 J. Epstein - Confidential understood that the statements made about Ms. Maxwell were false, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understood that those statements were false because Ms. Maxwell did not recruit Virginia Roberts to have sex with you, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understood that the statements were false because Ms. Maxwell did not assist anyone, including yourself, in sexually trafficking Virginia Roberts to any person, correct? MR. CASSELL: Object to form and foundation. And just so the record is clear, if I just use the words "form, foundation" -- MR. PAGLIUCA: That is fine with me. MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understand that Virginia Roberts was Page 291 J. Epstein - Confidential THE WITNESS: Fifth. MR. WEINBERG: And his -- and his state of mind is inseparable from attorney-client communications. MR. PAGLIUCA: Right. I'm not asking for any attorney-client communications, so we are clear. BY MR. PAGLIUCA: Q. I don't recall if I asked you or not, but I will ask you now: What were the terms of the settlement agreement between yourself and Ms. Giuffre/Roberts? A. Fifth. MR. GOLDBERGER: And the standing objection on confidentiality. MR. PAGLIUCA: Understood. BY MR. PAGLIUCA: Q. Mr. Epstein, you read Ms. Roberts’ -- Ms. Virginia Roberts'/Giuffre's statements published in the media about Ghislaine Maxwell, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. When you read those statements, Page 293 J. Epstein - Confidential not 15 when she claims to have met you, true? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understand that Virginia Roberts was not 16 at the time that she claims to have met you, correct? MR. CASSELL: Form, foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understand -- well, isn't it true that Ms. Roberts represented to you, at the time that she met you, that she was 18 years old? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Isn't it true that Ms. Roberts represented to others in your presence that she was over the age of 18? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Isn't it true that Ms. Roberts represented to Ms. Maxwell that she was over the age of 18? MAG NA® 74 (Pages 290 to 293) LEGAL SERVICES