Giuffre_Maxwell_Batch8_p00954.png

OMANDNRWNKE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 74 of 134 Page 286 J. Epstein - Confidential institute criminal charges against alleged potential co-conspirators in that matter, including Sarah Kellen, Adriana Ross, Leslie Goth (phonetic), or Nadia Marcinkova; is that correct? MR. CASSELL: Form and foundation. Calls for a legal conclusion. MR. WEINBERG: To the extent your knowledge is based on communications with attorneys, attorney-client privilege. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You were provided, Mr. Epstein, with a copy of the non-prosecution agreement that you entered into with the United States Government in 2007, correct? A. Fifth. MR. WEINBERG: Attorney-client privilege. BY MR. PAGLIUCA: Q. And you've read a non-prosecution agreement that you entered into with the United States Government in 2007 before you signed it, correct? A. Fifth. Q._ Ms. Maxwell was not identified by name in OANANHRWNH J. Epstein - Confidential a witness to testify in this case, correct? A. Fifth. MR. CASSELL: Object to form and foundation. Calls for a legal conclusion. MR. WEINBERG: The answer would be based on the attorney-client privilege communication. MR. GOLDBERGER: I think he said, the Fifth. THE COURT REPORTER: Okay. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And setting aside any communications that you may have had with any lawyers representing you, absent the efforts by Mr. Cassell and Edwards to have your non-prosecution agreement voided, you would be able to testify as a witness in this matter, correct? MR. CASSELL: Form and foundation. Calls for a legal conclusion. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Absent the efforts by Mr. Cassell and Mr. Edwards to void your non-prosecution agreement, you would be willing to testify as a witness in this Page 287 J. Epstein - Confidential the non-prosecution agreement, correct? A. Fifth. Q. And Ms. Maxwell was not identified in the non-prosecution agreement because she was not a conspirator in any crime, correct? MR. CASSELL: Form and foundation. Calls for a legal conclusion. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You are aware, from sources other than your lawyers, that Mr. Edwards, who is one of the Plaintiff's lawyers in this case, and Mr. Cassell, who has taken your deposition here today, are attempting to have your non-prosecution agreement with the United States Government voided, correct? A. Fifth. MR. CASSELL: Object to form and foundation. MR. GOLDBERGER: And attorney-client privilege. BY MR. PAGLIUCA: Q. Absent the attempts by Mr. Cassell and Edwards on behalf of their clients to void your non-prosecution agreement, you would be available as Page 289 J. Epstein - Confidential case, correct? MR. CASSELL: Form and foundation. Speculation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And absent the efforts by Mr. Cassell and Mr. Edwards to void your non-prosecution agreement, your willing, truthful testimony in this case would be helpful to Ms. Maxwell, correct? MR. CASSELL: Form. Foundation. Calls for a legal conclusion. Speculation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You were asked some questions by Mr. Cassell about the lawsuit by Ms. Roberts against you. It's true, is it not, that the allegations contained in that complaint against you by Ms. -- then Roberts or Giuffre were false, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And any allegations in that complaint by Ms. Giuffre/Roberts against you relating to MAG NA® 73 (Pages 286 to 289) LEGAL SERVICES