From: Sigrid McCawley
To:

Subject: FW: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version) Date: Mon, 23 Mar 2020 21:28:16+0000 Attachments: Maxwell_Dep. Tr._(Slip_and_Fall_Case).pdf

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Hi - my paralegal found this. Not sure if you have it so I wanted to pass it along. It's a 2019 depo of Maxwell in a slip and fall case in NYC. There are some clips below and the full version is attached.

Best,
Sigrid

Sigrid McCawley
Partner

BOIES SCHILLER FLEXNER LLP

Fort Lauderdale, FL, 33301

From: Sandra Perkins Sent: Monday, March 23, 2020 5:13 PM To: Sigrid McCawley Sabina Mariella Subject: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)

Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)

Note the File # has an AIG PRIV prefix (this has to mean that AIG is her insurance carrier on this case).

CUOMO, LLC.

Attorney for Defendant

Mineola, New York 11501

BY: MATTHEW CUOMO, ESQ.

FILE NO.: AIGPRIV 17007

EFTA00011497

1

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

SHELDON BARR and THOMAS GARDNER,

Plaintiffs,

-against-

CITY OF NEW YORK and

Defendants,

INDEX NO.: 159225/2010

-x

New York, New York

April 9, 2019

10:07 a.m.

EXAMINATION BEFORE TRIAL of the Defendant,

by GHISLAINE MAXWELL, in

the above-entitled action, held at the above time

and place, taken before a Notary Public of the State

of New York, pursuant to order and Stipulations

between Counsel.

Page 9 (Primary residence as of 9/2015 NY)

EFTA00011498

Q. What was your primary residence back in

September of 2015?

A.

Q. Can you tell me how much time you spent there, say, back in 2015 from January 1st through September 9, 2015?

A. A lot of time. I lived there. That's my

primary residence.

## Page 10 (Maxwell is a US Citizen as well as citizen of France and England)

	Q. Where were you born?

	A. Paris, France.

	Q. What is your date of birth?

	- A.

	Q. Are you a U.S. Citizen at this time?

	A. Yes.

Q. When did you become a U.S. Citizen?

A. I don't recall. But it was some time in

e late '90s, mid '90s. I'm not sure. I don't

nember.

	Q. Are you a citizen of any other country?

	A. Yes.

	Q. What other countries?

	A. France and England.

Page 11 Education and Licenses

EFTA00011499

Q. Do you have any professional degrees or

licenses?

	A. I do.

	Q. In what?

A. I'm a registered emergency technician, first responder, EMT. I'm a helicopter pilot.

	Q. Sorry?

	A. Helicopter pilot.

Q. Is your certification as an EMT in the

United States or another country?

	A. In the U.S.

## Page 12 - Ellmax

<table><tr><th>10</th><th>Q.</th><th>What is Ellmax?</th></tr><tr><td>11</td><td>A.</td><td>It's no longer in existence.</td></tr><tr><td>12</td><td>Q.</td><td>What was it?</td></tr><tr><td>13</td><td>A.</td><td>It was a company I started to advise other.</td></tr><tr><td>14</td><td>businesses</td><td>on board placement, placing board of</td></tr><tr><td>15</td><td>directors,</td><td>and any other questions they might have,</td></tr><tr><td>16</td><td>conferences,</td><td>locations for conferences, speakers at</td></tr><tr><td>17</td><td>conferences.</td><td></td></tr><tr><td>18</td><td>Q.</td><td>What is the primary business? Is it</td></tr><tr><td>19</td><td>Ellmax,</td><td>LLC.?</td></tr><tr><td>20 22</td><td>A.</td><td>I think so.</td></tr><tr><td>21</td><td>8.</td><td>Is that a Florida Limited Liability</td></tr><tr><td>22</td><td>Company?</td><td></td></tr><tr><td>23</td><td>A.</td><td>Whatever paperwork I have. I don't recall.</td></tr><tr><td>24</td><td>Whatever</td><td>it says on the paperwork.</td></tr></table>

10

11

12

13

14

15

16

18

22

20 20

21 21

22

23

EFTA00011500

Page 16- personal assistant for more than 10 years (beginning 2001 or 2002) and
Maxwell paid herself not through Ellmax.
(Proof of payments?)

## GHISLAINE MAXWELL

Who is

A. my personal assistant.

Q. How long was your personal assistant?

A. More than ten years.

o. More than ten years from today?

A. No. doesn't work for me anymore.

Q. When did you start working for you?

A. Again, some time in 2001, 2002. Something

like that.

Q. Was your personal assistant for the

next ten years?

A. Yeah.

Q. Was paid by Ellmax, LLC.?

A. I paid myself.

Q. Did you pay out of a different company

or different funds or what source?

A. I don't recall where I paid from

exactly. was not an employee of -- I was the

only person that did any work for Ellmax. was

my personal assistant. was able would do

Page 18 (Ellmax Florida Corporation – Maxwell stated that she lived in number of place in Florida)

EFTA00011501

## GHISLAINE MAXWELL (cont.)

9 9. Was there a reason you chose a Florida

10 Limited Liability Company for Ellmax, LLC.?

11 A. I don't know why. I don't remember.

12 Q. Were you also a Florida resident back in

13 2016?

14 A. I lived in Florida at certain times since I

15 moved to the states.

16 Q. What is your address in Florida?

17 A. I lived in a number of different places in

18 Florida.

19 8. Do you own real estate in Florida?

20 20 A. No.

21 22 Q. At any point did you maintain a residence

22 22 in Florida?

23 A. I've never owned a home in Florida.

24 Q. Did you rent the same residence in Florida?

25 A. No.

Page 23 (Communicated with her personal assistant via email, text or phone) Where are the records?

EFTA00011502

1 GHISLAINE MAXWELL

2 Q. You said was your personal assistant.

3 A. I did.

4 8. Was that a remote job or did live with

5 you or lived nearby?

6 A. never lived in my home. I can't

7 recall. Wherever lived I don't know. I'm

8 sorry.

9 Q. Was it a full-time or part-time job?

10 A. It was full-time.

11 Q. How would you communicate with

.2 A. Via, email, text, or phone.

Page 25: Darren Indyke helped Maxwell create Ellmax

EFTA00011503

## GHISLAINE MAXWELL (cont.)

Page 25
April 9, 2019

1 GHISLAINE MAXWELL

2 0. Was there ever any other members?

3 A. I don't believe so.

4 O. Could you tell me who Darren Indyke, Esq.

5 at New York, New York is? Could

6 you tell me who he is?

7 A. He is a lawyer.

8 8. What is his connection with the LLC?

9 A. He helped create it.

10 Q. Did you hire him to create it?

11 A. I don't recall how it went down exactly.

12 How he came to do it. But, he was the lawyer. And

13 he helped create it.

14 O. Was he referred to you by somebody?

15 A. He worked for a friend of mine.

16 0. Who is that?

17 A. A gentlemen called Mr. Epstein.

## Page 31 (Miami Beach address in 2014)

<table><tr><th colspan="3">0. What is the address at</th></tr><tr><td>10</td><td></td><td>Miami Beach, Florida 33139?</td></tr><tr><td>11</td><td>A.</td><td>That was a home that I rented for a short</td></tr><tr><td>12</td><td>while,</td><td>and I stayed at the address.</td></tr><tr><td>13</td><td>Q.</td><td>When did you rent it?</td></tr><tr><td>14</td><td>A.</td><td>I don't recall the dates. I am sorry.</td></tr><tr><td>15</td><td>Q.</td><td>Was it in the year 2014.</td></tr><tr><td>16</td><td>A.</td><td>I honestly don't remember.</td></tr></table>

Page 32 (Douglas Elliman was broker for sale of NY home)

EFTA00011504

## Page 31 (Miami Beach address in 2014) (cont.)

11 8. Was that based on your accountant or a

12 legal advise or on your own?
232
13 A. I'm sure that was based on legal advise.

14 d. Did you have a lawyer that formed it for

15 you?

16 A. You are asking things to go back over 20

17 years. I don't recall exactly how it went down.

18 Q. Did you utilize the services of a broker in

19 purchasing

20 A. I don't remember.

21 8. Did you utilize the services of a broker

22 when selling

23 22 A. I did.

24 d. Was that Douglas Elliman?

25 A. It was.

Page 40 (Odd that she says not married at the time ... could she be married now)?

EFTA00011505

Page 40

April 9, 2019

1 GHISLAINE MAXWELL

2 A. No.

3 Q. Who lived in on

4 September 9, 2015?

5 A. Excuse me?

6 Q. Are you married?

7 A. I was not married at the time of this.

8 Q. Do you have any children?

9 A. No.

10 Q. Did you have any help that lived in the

11 house with you?

12 A. No.

13 Q. Did you have a housekeeper?

14 A. I did have a housekeeper, yes.

15 Q. Live out or live in?

16 A. Out.

## Page 47 (says she used a MAC or laptop in 2015) (for ESI)

<table><tr><th>15</th><th>o.</th><th>Were there computers kept in that office?</th></tr><tr><td>16</td><td>A.</td><td>There was a computer in that office.</td></tr><tr><td>17</td><td>Q.</td><td>What kind of computer was it?</td></tr><tr><td>18</td><td>A.</td><td>I think it was a Mack.</td></tr><tr><td>19</td><td>Q.</td><td>Was it a laptop or desktop?</td></tr><tr><td>20</td><td>A.</td><td>I think it was a desk top. It could have</td></tr><tr><td>21 22</td><td>been a</td><td>laptop. I don't know.</td></tr><tr><td>22</td><td></td><td>Who owned that desktop?</td></tr><tr><td>23 22</td><td>A.</td><td>Well, if it was a desk top it would have</td></tr><tr><td>24</td><td>been me.</td><td>Actually I think it was laptop in 2015.</td></tr><tr><td>25</td><td>O.</td><td>Back in September of 2015, was there a desk</td></tr></table>

EFTA00011506

## Maxwell had a filing cabinet (hard copy records)

	A. I didn't have business records.

Q. Where did you keep the records for Ellmax,

LLC.?

A. I use to move my I had a file cabinet wherever I was sitting. I had a filing cabinet.

Q. Where would that be kept? On what floor in the building?

A. It moved. I frequently moved my desk. I couldn't decide where I would sit. There was a period of time in the dining room became a place where I would sit and the library. When I moved my desk my little filing system cop come with me.

Page 52-53 (Tax returns reflect Maxwell claiming to work 60 hour weeks for Terramar)

EFTA00011507

## Maxwell had a filing cabinet (hard copy records) (cont.)

15

16

17

18

19

20

21

22 22
22

23 23

24

25

Q. Referring to the bottom portion next to the

yellow label of Plaintiff's Exhibit 10. Directing

your attention to Page 8 of the tax return. Do you

see this page?

A. I do.

8. Did you indicate in this tax return that

you worked 60 hours a week on the Terramar Project?

A. Yes.

0. Did you have other officers at that time

that worked for the Terramar Project?

A. Well, done 23 hours.

DEITZ Court Reporting... A Lexitas Company
800-678-0166

YORK COUNTY CLERK 03/05/2020 12:59 PM INDEX NO. 159224/2016
113 RECEIVED NYSCEF: 03/05/2020
Page 53
April 9, 2019

GHISLAINE MAXWELL

2 O. Is that accurate?

3 A. I'm sure it is.

Page 54-55 Claims only "contract contractors" who paid for work - but she and other board members did not receive compensation.

EFTA00011508

25

A. These are just all directors and none of

DEITZ Court Reporting... A Lexitas Company
800-678-0166

## YORK COUNTY CLERK 03/05/2020 12:59 PM

INDEX NO. 159224/2016

. 113

RECEIVED NYSCEF: 03/05/2020
Page 55
April 9, 2019

GHISLAINE MAXWELL

them were renumerated. Nobody was paid. But,

Terramar Project did have work called contract

contractors who did do work for it. A contract

employee or contract person that worked for the

company is not the same as a regular employee. They

wouldn't come to work.

O. Who was that?

A. I have had a number of I had a number of

different people. We also have one person who did

work for Terramar Project. They were always

offsite, because they would never come to work.

They would be remote.

2

3

4

5

6

7

8

9

10

11

12

13

Page 55: Robert Foos was a contracted employee for Terramar (Director of Development) Who paid him?

EFTA00011509

## YORK COUNTY CLERK 03/05/2020 12:59 PM (cont.)

15

<table><tr><th colspan="3">14 0. Were there any contracting employees back</th></tr><tr><td>15</td><td>in 2015</td><td>for Terramar Project, Inc.?</td></tr><tr><td>16</td><td>A.</td><td>There were, yes.</td></tr><tr><td>17</td><td>Q.</td><td>Who were they?</td></tr><tr><td>18</td><td>A.</td><td>One. I believe it was Robert Foos.</td></tr><tr><td>19</td><td>0.</td><td>In what position did he hold?</td></tr><tr><td>20</td><td>A.</td><td>I think his official title was Director of</td></tr><tr><td colspan="3">222

21 Development.</td></tr><tr><td>22</td><td>8.</td><td>Does the additional data sheet indicate</td></tr><tr><td>23</td><td>that you</td><td>were also working 60 hours a week for</td></tr><tr><td>24 22</td><td>Terramar</td><td>Project back in 2013?</td></tr><tr><td>25</td><td>A.</td><td>Yes.</td></tr></table>

16

19 19

222 20 20

21 21

DEITZ Court Reporting... A Lexitas Company
800-678-0166

YORK COUNTY CLERK 03/05/2020 12:59 PM

113

INDEX NO. 159224/2016

RECEIVED NYSCEF: 03/05/2020

Page 56

April 9, 2019

GHISLAINE MAXWELL

Page 57-58 (Mark, Paneth & Shron prepared her taxes for Terramar)

EFTA00011510

## YORK COUNTY CLERK 03/05/2020 12:59 PM (cont.)

23 Q. Was the accountant that prepared it Mark,

24 Paneth & Shron, LLP., New York,

25 New York 100017, as indicated on Plaintiff's Exhibit

DEITZ Court Reporting... A Lexitas Company
800-678-0166

## YORK COUNTY CLERK 03/05/2020 12:59 PM

INDEX NO.

113

RECEIVED NYSCEF:
Page 58
April 9, 2019

<table><tr><th>1</th><th colspan="2">GHISLAINE MAXWELL</th></tr><tr><td>2</td><td>107</td><td></td></tr><tr><td>3</td><td>A.</td><td>It may have been.</td></tr><tr><td>4</td><td>O.</td><td>Were they your accountants?</td></tr><tr><td>5</td><td>A.</td><td>They were.</td></tr><tr><td>6</td><td>Q.</td><td>Do they always file your personal tax</td></tr><tr><td>7</td><td>returns</td><td>and the tax returns for the Terramar</td></tr><tr><td>8</td><td>Project?</td><td></td></tr></table>

## Page 66 (Discussed deed being titled as



15 Q. When it was purchased in 2000, do you

16 recall if you purchased it using

17 LLC.?

18 A. I believe I did.

19 0. Were you the sole member of

20 LLC.?

222 21 A. Yes.

22 Q. Were you advised either by a lawyer or an

23 accountant to purchase the home through an LLC?

24 A. I don't recall, but I'm sure I was.

Page 70

EFTA00011511

NO. 113

RECEIVED NYSCEF: 03/05/2020
Page 70

April 9, 2019

## Page 66 (Discussed deed being titled as (cont.)

<table><tr><th>1</th><th>GHISLAINE MAXWELL</th></tr><tr><td>2</td><td>Q. When in town is that where you would sleep?</td></tr><tr><td>3</td><td>A. Yes.</td></tr><tr><td>4</td><td>Q. You had your master bedroom in the house at</td></tr><tr><td>5</td><td></td></tr><tr><td>6</td><td>A. Yes.</td></tr><tr><td>7</td><td>O. That was all the time between 2000 thru</td></tr><tr><td>8</td><td>2016?</td></tr><tr><td>9</td><td>A. Yes.</td></tr><tr><td>10</td><td>Q. With respect to the Terramar Project, did</td></tr><tr><td colspan="2">11 you ever collect or have you ever collected any</td></tr><tr><td>12</td><td>salary as the president of the Terramar Project?</td></tr><tr><td>13</td><td>A. No.</td></tr><tr><td colspan="2">Page 73-74</td></tr><tr><td>14</td><td>Q. Have you received any remuneration of any</td></tr><tr><td colspan="2">15 kind from the Terramar Project for your service for</td></tr><tr><td colspan="2">16 that not-for-profit entity?</td></tr><tr><td>17</td><td>A. No.</td></tr><tr><td>18</td><td>Q. Is there any place in the home, at</td></tr><tr><td>19</td><td>that is set aside for use solely by the</td></tr><tr><td>20</td><td>Terramar Project?</td></tr><tr><td>21</td><td>A. No.</td></tr></table>

EFTA00011512

## Page 66 (Discussed deed being titled as (cont.)

25 25 25

0. When you worked for a particular company,

DEITZ Court Reporting... A Lexitas Company
800-678-0166

## YORK COUNTY CLERK 03/05/2020 12:59 PM

INDEX NO. 1592

. 113

RECEIVED NYSCEF: 03/
Page 74
April 9, 2019

<table><tr><th colspan="3">1 GHISLAINE MAXWELL</th></tr><tr><td>2</td><td>did you work</td><td>with them at their premises?</td></tr><tr><td>3</td><td>A. Yes.</td><td></td></tr><tr><td>4</td><td>Q. Did</td><td>you ever had them come to your</td></tr><tr><td>5</td><td>business, to</td><td>to do that work?</td></tr><tr><td>6</td><td>A. No.</td><td></td></tr></table>

EFTA00011513

## YORK COUNTY CLERK 03/05/2020 12:59 PM (cont.)

7

8. During the period of time that Ellmax- functioned, did it generate revenue?

B

9

A. A small amount.

10

Q. Did you ever collect a salary for Ellmax?

A. No.

11

12

Q. Were you ever disbursed any profits from

13 Ellmax?

14

A. No.

15

Q. What happened to the revenue that Ellmax generated during that period of time, from 2010 to

16

17 2013?

18

A. It just was used to defer cost such as traveling and travel mostly.

19

20

Q. What were the costs of travel related to Ellmax where you were going?

21

22

A. Sorry, most of the companies I would have worked for were from Los Angeles. I went to LA and also to London multiple times.

23

24

Page 76-77 (Monte Albers De Leon closing lawyer for house/Maxwell did not attend closing).

EFTA00011514

19 Q. Did you attend the closing when you sold

20 the building at
2222
21 A. NO.

Q. Did you authorize somebody to attend the

23 23 closing for you?

24 A. Yes.
22
25 Q. Who was that?

DEITZ Court Reporting... A Lexitas Company
800-678-0166

YORK COUNTY CLERK 03/05/2020 12:59 PM INDEX NO. 159224/:
113 RECEIVED NYSCEF: 03/05/:
Page 77
April 9, 2019

1 GHISLAINE MAXWELL

2 A. The lawyer that is on that. I don't

3 remember his name. Monte Albers De Leon.

4 Q. Who is he? Is he your lawyer?

5 A. He was a lawyer that I used.

## Sandra Perkins Borger

Case Manager

## BOIES SCHILLER FLEXNER LLP



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