From: Sigrid McCawley
To: <empty>
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

EFTA00011365

- Court: Supreme Court of the State of New York, County of New York  
- Case caption: Plaintiffs [REDACTED] v. City of New York and [REDACTED] (defendants) — several names are blacked out on the page  
- Index No.: 159225/2010  
- Location & timestamp: New York, New York — April 9, 2019 — 10:07 a.m. (date highlighted)  
- Document type: "Examination before trial of the Defendant"  
- Examiner: name shown and highlighted on the page (redacted in image)  
- Other highlighted text: "pursuant to Order and Stipulations"  
- Visible redactions: multiple black bars over defendant name(s) and a block near the top of the page

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

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

Q. Are you a citizen of any other country?

A. Yes.

0. What other countries?

A. France and England.

## Page 11Education and Licenses

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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

Q. What is Ellmax?

A. It's no longer in existence.

Q. What was it?

A. It was a company I started to advise other.

businesses on board placement, placing board of

directors, and any other questions they might have,

conferences, locations for conferences, speakers at

17 conferences.

Q. What is the primary business? Is it

19 Ellmax, LLC.?

A. I think so.

8. Is that a Florida Limited Liability

Company?

A. Whatever paperwork I have. I don't recall.

24 Whatever it says on the paperwork.

10

11

12

13

14

15

16

18

20
22

21

22

23

EFTA00011368

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.

Q. -

A.  my personal assistant.

Q. How long was your personal assistant?

A. More than ten years.

Q. 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 .n 2001, 2002. Something

like that.

Q. Was your personal assistant for the next ten years?

A. Yeah.

Q. Was paid by Ellmax, miLC.?  [ ]

A. I paid myself.

Q. Did you pay out of a different company

or different funds or what source?

Key statements from the text:

*   "I don't recall where I paid from exactly."
*   "[Blacked out] was not an employee of -- I was the only person that did any work for Ellmax."
*   "[Blacked out] was my personal assistant."
*   "[Blacked out] was able -- [Blacked out] would do"

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

EFTA00011369

<table><tr><th>9</th><th>9.</th><th>Was there a reason you chose a Florida</th></tr><tr><td>10</td><td>Limited</td><td>Liability Company for Ellmax, LLC.?</td></tr><tr><td>11</td><td>A.</td><td>I don't know why. I don't remember.</td></tr><tr><td>12</td><td>Q.</td><td>Were you also a Florida resident back in</td></tr><tr><td>13</td><td>2016?</td><td></td></tr><tr><td>14</td><td>A.</td><td>I lived in Florida at certain times since I</td></tr><tr><td colspan="3">15 moved to the states.</td></tr><tr><td>16</td><td>Q.</td><td>What is your address in Florida?</td></tr><tr><td>17</td><td>A.</td><td>I lived in a number of different places in</td></tr><tr><td>18</td><td>Florida.</td><td></td></tr><tr><td>19</td><td>8.</td><td>Do you own real estate in Florida?</td></tr><tr><td>20 20</td><td>A.</td><td>No.</td></tr><tr><td>21 22</td><td>Q.</td><td>At any point did you maintain a residence</td></tr><tr><td colspan="3">22 22 in Florida?</td></tr><tr><td>23</td><td>A.</td><td>I've never owned a home in Florida.</td></tr><tr><td>24</td><td>Q.</td><td>Did you rent the same residence in Florida?</td></tr><tr><td>25</td><td>A.</td><td>No.</td></tr></table>

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

EFTA00011370

The image is a document from a deposition of Ghislaine Maxwell.

Key information:

*   Subject: Ghislaine Maxwell
*   Topic: Maxwell's personal assistant's living arrangements and job type.
*   The assistant did not live with Maxwell, and Maxwell doesn't recall where the assistant lived.
*   The job was full-time.
*   Communication with assistant: Via email, text, or phone.

Page 25: Darren Indyke helped Maxwell create Ellmax

EFTA00011371

Page 25
April 9, 2019

Ghislaine Maxwell deposition:
*   Darren Indyke, Esq. is a lawyer in New York, New York.
*   Indyke helped create the LLC.
*   Indyke was referred by Mr. Epstein.

Page 31(Miami Beach address in 2014)

- Document: deposition transcript (lines 9–16)
- Q: What is the address at [REDACTED] Miami Beach, Florida 33139?
- A: That was a home that I rented for a short while, and I stayed at the address.
- Q: When did you rent it?
- A: I don't recall the dates. I am sorry.
- Q: Was it in the year 2014?
- A: I honestly don't remember.

Context notes:
- Page 31: Miami Beach address referenced with possible 2014 timeframe.
- Page 32 (surrounding text): Douglas Elliman was broker for sale of NY home.

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

EFTA00011372

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)?

EFTA00011373

Page 40

April 9, 2019

The image shows a transcript of Ghislaine Maxwell's testimony. Key points include her statement that she was not married at the time of the deposition, and that she had a live-out housekeeper.

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

- Key points:
  - A computer was kept in the office.
  - Witness thinks it was a "Mack" (Mac).
  - Uncertain whether it was a desktop or laptop; initially says desktop, then says it could have been a laptop.
  - If it were a desktop, the witness says they would have owned it; they later think it was a laptop in 2015.
  - Question reference: September 2015.

- Transcribed Q/A (lines shown):
15 Q. Were there computers kept in that office?
16 A. There was a computer in that office.
17 Q. What kind of computer was it?
18 A. I think it was a Mack.
19 Q. Was it a laptop or desktop?
20 A. I think it was a desk top.  It could have been a laptop.  I don't know.
22 Q. Who owned that desktop?
23 A. Well, if it was a desk top it would have been me.  Actually I think it was laptop in 2015.
25 Q. Back in September of 2015, was there a desk

EFTA00011374

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

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

EFTA00011375

15 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?
19 A. I do.
20 Q. Did you indicate in this tax return that you worked 60 hours a week on the Terramar Project?
21 A. Yes.
23 Q. Did you have other officers at that time that worked for the Terramar Project?
24 A. Well, <empty> 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

1 GHISLAINE MAXWELL
2 Q. 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.

EFTA00011376

- Question: "These are just all directors and none of"
- Company: DEITZ Court Reporting, A Lexitas Company
- Phone: 803-678-0166

803-678-0166

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

2 them were renumerated. Nobody was paid. But,

3 Terramar Project did have work called contract

4 contractors who did do work for it. A contract

5 employee or contract person that worked for the

6 company is not the same as a regular employee. They

7 wouldn't come to work.

8 O. Who was that?

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

10 different people. We also have one person who did

11 work for Terramar Project. They were always

12 offsite, because they would never come to work.

13 They would be remote.

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

EFTA00011377

*   **2015 Terramar Project:** There were contracting employees.
*   **Robert Foos:** Was a contracting employee; Director of Development.
*   **2013 Terramar Project:** The subject worked 60 hours/week.

DEITZ Court Report1mg... A Lexitas Company
800-6/8-0166

YORK COUNTY CLERK 03/05/2020 12:59 PM
INDEX NO. 159224/2016
113
RECEIVED NYSCEF: 03/05/2020
Page 56
April 9, 2019
1 GHISLAINE MAXWELL

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

EFTA00011378

Question: Was the accountant Mark, Paneth & Shron, LLP from New York, NY 100017?
Plaintiff's Exhibit referenced.
Deitz Court Reporting, a Lexitas Company.

800-678-0166

## YORK COUNTY CLERK 03/05/2020 12:59 PM
113

INDEX NO.

RECEIVED NYSCEF:
Page 58
April 9, 2319

1  CHISLAINE MAXWELL
2 10?

3 A. It may have been.

4 Q. Were they your accountants?

5  A.  They were.
6 Q. Do they always tile your personal tax
7 returns  and the tax returns for the Terramar

8 Project?

Page 66 (Discussed deed being titled as

Key points from the text:

*   A property was purchased in 2000.
*   The purchase may have been made using an LLC.
*   The person believes they were the sole member of the LLC.
*   The person was possibly advised to purchase the home through an LLC.

Page 70

EFTA00011379

NO. 113

RECEIVED NYSCEF: 03/05/2020 
Page 7C

April 9, 2019

1 GHISLATNE MAXWELL
2 Q. When in town is that where you would sleep?

3 A. Yes.

4 Q. You had your master bedroom in the house at

5 
6 A. Yes.
7 O.  That was all the time between 2000 thru
8  2016? 
9 A. Yes.

10 Q. With respect to the Terramar Project, did

11 you ever collect or have you ever collected any

12 salary as the president of the Terramar Project?
13 A. No.

Page 73-74

14  Q. Have you received any remaavrat ion of uny

15  kind from the Terramar Project for your servic'• for

16 that not-for-profit entity?

17 A. No.

18 Q. Is there any place in the home, at

19 that is set aside for use solely by the

20 Terramar Protect?

21 A. No.

EFTA00011380

The image shows the text:

"Q. When you worked for a particular company,"

DEITZ Court Reporting... A Lexitas Company
800-678-0366

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

INDEX NO. 159:

. 113

RECEIVED NYSCEF: 03,
Page 74

April 9, 2019

The image shows an excerpt from a deposition with Ghislaine Maxwell.

| Question | Answer |
|---|---|
| Did you work with them at their premises? | Yes |
| Did you ever have them come to your business, to [redacted] to do that work? | No |

EFTA00011381

<table><tr><th>7</th><th>8.</th><th>During the period of time that Ellmax-</th></tr><tr><td>B</td><td colspan="2">functioned, did it generate revenue?</td></tr><tr><td>9</td><td colspan="2">A. A small amount.</td></tr><tr><td>10</td><td>Q.</td><td>Did you ever collect a salary for Ellmax?</td></tr><tr><td>11</td><td>A.</td><td>No.</td></tr><tr><td>12</td><td>Q.</td><td>Were you ever disbursed any profits from</td></tr><tr><td>13</td><td>Ellmax?</td><td></td></tr><tr><td>14</td><td>A.</td><td>No.</td></tr><tr><td>15</td><td>Q.</td><td>What happened to the revenue that Ellmax</td></tr><tr><td>16</td><td>generated</td><td>during that period of time, from 2010 to</td></tr><tr><td>17</td><td>2013?</td><td></td></tr><tr><td>18</td><td>A.</td><td>It just was used to defer cost such as</td></tr><tr><td>19</td><td>traveling</td><td>and travel mostly.</td></tr><tr><td>20</td><td>Q.</td><td>What were the costs of travel related to</td></tr><tr><td>21</td><td>Ellmax</td><td>where you were going?</td></tr><tr><td>22</td><td>A.</td><td>Sorry, most of the companies I would have</td></tr><tr><td>23</td><td>worked</td><td>for were from Los Angeles. I went to LA and</td></tr><tr><td>24</td><td>also to</td><td>London multiple times.</td></tr></table>

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

EFTA00011382

The image shows a transcript of a deposition.

*   **Q1:** Did you attend the closing when you sold the building at [BLOCKED]?
    **A1:** No.
*   **Q2:** Did you authorize somebody to attend the closing for you?
    **A2:** Yes.
*   **Q3:** Who was that?

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

Key details from the image:

*   **Subject:** Ghislaine Maxwell
*   **Lawyer Mentioned:** Monte Albers De Leon
*   **Context:** A deposition transcript, where Maxwell states she doesn't remember the lawyer's name and confirms he was a lawyer she used.
*   **Date:** April 9, 2019
*   **Filing Date:** March 5, 2020
*   **Index Number:** 159224

Sandra Perkins Borger, Case Manager at BOIES SCHILLER FLEXNER LLP.

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EFTA00011383