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113 o22017 1 Jeffrey Epstein where -- where this seemed to be going 22019 2 onand was very close to Epstein, staying at the mansion 022022 3 frequently. 022023 4 And so she would, obviously, be -- I guess if 022023 § you have Epstein at the -- the top of the -- you know, o22027 § the kingpin of the operation, Maxwell would be, you 022030 7 know, a close second or certainly at, you know, the 022032 8 higher echelon. 22033 9 So, obviously, someone who would have, you 22033 10 know, very significant information about, you know, the 022033 14 sex trafficking, who were the other people that the -- 022041 12 the girls were being trafficked to, what kind of abuse 02:20:43 13 was going on, you know, what kinds of sex toys were 022046 14 being used to abuse them, because I think it was in her 022048 15 room or -- or adjacent to her room that many of these -- o22082 16 these devices were located, and so she would have had 022055 17 very significant information to provide. 02.2057 18 And so in connection with the civil cases 022100 19 that some of the girls had filed against Mr. Epstein, 022102 20 her deposition was set, in fact, by my co-counsel, e22105 21 Mr. Edwards, and then there was some haggling over a o22i10 22 confidentiality agreement, you know, what are we e222 23 gonna -- and that had all been worked out, and then she o22i14 24 was set for a deposition and finally agreed, you know, o22116 25 to a deposition. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 114 ozaii7 1 And just shortly, you know, I think a couple eae 2 of days before that deposition, she canceled. And well, 022123 3 she didn't cancel. Her -- her attorney called to cancel 022128 4 the deposition and represented that Miss Maxwell was o22120 5 outside the United States of America and had no plans to o2213a § return back to the United States. o22i35 «7 And $0, at that point, the deposition was -- o22140 8 was not able to go forward. But it turned out that she o22143 9 had not left the United States for an extended period of o22146 10 time. She was spotted later at a wedding of a prominent o22149 11 person in New York. ozaiso 12 And so that was Maxwell fitting into this 02:21:52 13 pattern of, you know, Epstein was being told -- you 022156 14 know, the Palm Beach Police Department being told by 022157 15 Dershowitz that Epstein will answer your questions, and o22200 16 then, you know, not -- not getting information, Maxwell 022203 17 evading the deposition. 022206 18 Jean Luc Brunel was another person who seemed 22200 19 to be very much involved in -- in trafficking the girls, o2z2210 20 and it was the same situation. A deposition was set to 022213 21 ‘try to get answers, you know, who is involved, which 022216 22 girls are involved, what are their names, what's -~ 022217 23 what's going on? o2:22:18 24 And so Brunel's deposition is set and then 022223 25 he -~ he finagles out of it too. I don't recall exactly ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 29 of 38 sheets 02:22:28 02:22:31 02:22:33 02:22:35 02:22:39 02:22:38 02:22:42 ON Oh WN A 02:22:44 © 02:22:46 10 02:22:52 1 1 02:22:49 o22257 12 o2zss 13 o22a01 14 oz2303 15 o2230s 16 22011 17 22313 18 o22317 19 022318 20 oz2a1e 24 o22322 22 022326 23 oz2a28 24 oz2aa4 25 02:23:38 02:23:43 02:23:47 02:23:52 02:23:54 02:23:57 02:24:00 On Oa kh WH = 02:24:01 o 02:24:03 10 oz2ao7 14 o22a1 12 o22at6 13 e227 14 15 16 17 o22427 18 022431 19 oz2aa7 20 oz2aas 21 or2zaar 22 oz2aag 23 erase 24 oz2ase 25 02:24:05 02:24:19 02:24:24 02:24:24 Page 113 to 116 of 151 115 what his excuse was, but, you know, evaded the deposition and, in fact, later information came to light he was hiding out in, you know, in the mansion of Epstein while he's claiming he's unavailable for -- for deposition. So -- so this pattern of Mr. Dershowitz, you know, where there were three attempts to obtain information from him, if that's all I had, I guess that would have been one thing. But what I had was a pattern of people who were implicated in this sex trafficking ring evading questions, you know, quite in violation of court orders and depositions and things -- I shouldn't say court order -- in violation of the deposition notices that were being sent and agreements being made, you know, through counsel. And then in addition to that, I had this, so why -- why would you think that, you know, there's this sex trafficking, you know, ring going on? It sounds kind of farfetched. Well -- well, one of the things that I had available to me on December 30th was a photograph that was widely available on the Internet, and that photograph depicted three people. It depicted Glenn Maxwell, Prince Andrew, and Virginia Roberts, and the -- at the time that it looked ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 116 like Virginia Roberts was an underage girl. She was not dressed in formal attire. And Prince Andrew had his arm around her, I think if memory serves, and right next -- smiling in the background is Miss Maxwell, and it appeared that that was a private residence, presumably in London, close to Buckingham Palace where -- where Prince Andrew lived. And so here was Prince Andrew with this underage girl with Glenn Maxwell, the -- the right-hand girl, if that's the right expression -- I probably should say -- strike that -- right-hand woman of -- of -- of Mr. Epstein -- that were there and somebody had taken the photograph. Given the surrounding circumstances, I thought perhaps Mr. Epstein had taken the photograph. So that would have shown Virginia Roberts's sexual abuse was not confined just to Florida, not confined to the New York mansion; it would have -- it would have presumably continued into London where one of, you know, the highest, most powerful persons in the governmental structure that -- that exists in England was now involved in -- in sexual abuse. And so that created grave concern about, how far did this sex trafficking ring reach; what were their connections; what were their abilities to influence, you ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:07:28 PM HOUSE_OVERSIGHT_010838