Giuffre_Maxwell_Batch8_p00970.png

OMAINDUNRWNE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 90 of 134 Page 350 J. Epstein - Confidential BY MR. CASSELL: Q. She had threesomes with you and another women, correct? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And the other woman was not a. was she? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Who was the other woman in the threesomes that you had in this period of time with Ms. Maxwell? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The only reason Ms. Maxwell consented to have threesomes with you was that she was your girlfriend at the time, right? MR. PAGLIUCA: Object to form and foundation. OMINDNKRWNK Page 352 J. Epstein - Confidential Q. Haley Robson reported to Ghislaine Maxwell, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Ghislaine Maxwell controlled Haley Robson, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Ghislaine Maxwell used Haley Robson to help bring girls to you for sex, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. What was Haley Robson's role in your household affairs? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. Page 351 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: Q. She was, in fact, your girlfriend from the late -- I'm sorry, from around 1996 to around 2005, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In fact, she actually continued to be your girlfriend into -- into 2006, 2007? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. When did you stop considering Ms. Maxwell to be your girlfriend? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Mr. Pagliuca asked you some questions about Haley Robson. Do you recall those questions? A. Yes. Page 353 J. Epstein - Confidential BY MR. CASSELL: Q. Mr. Pagliuca asked you some questions about whether you are an easy target for lawsuits. Do you recall those questions? A. Yes. Q. One of the reasons you were an easy target for lawsuits, sir, was that you sexually abused dozens and dozens of underage girls, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. One of the reasons you were an easy target for Virginia Roberts for sexual assault is because you had, in fact, committed sexual assault against Virginia Roberts? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You settled dozens of lawsuits filed against you by underage girls in 2008 and 2009, didn't you? MR. PAGLIUCA: Object to form and MAG NA® 89 (Pages 350 to 353) LEGAL SERVICES