# Potential Perjury by Maxwell

## 4/22/16 deposition

## pp. 13-14

Q. Did you ever invite anybody who was

17 under the age of 18 to Jeffrey's homes? 18 MR. PAGLIUCA: Same objections. 19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come. 24 Q. Anybody that is not a friend of 25 yours. Any female under the age of 18, did 3 you invite them to come to Jeffrey's home? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. Again, as I said, I am not aware of 7 inviting anybody other than friends of mine 8 who have children to the house.

## P. 27

Are you testifying that you are

9 unaware of any underage, under the age of 18, 10 females coming to Jeffrey Epstein's home to 11 perform massages? 12 MR. PAGLIUCA: Object to the form 13 foundation. 14 A. You need to straddle that question 15 in a different time period. When I was 16 there, at the time I was present, the people 17 that gave Jeffrey, men and women who gave 18 Jeffrey massages were adults over the age of 19 18.

## pp. 37-38

Q. Ms. Maxwell, when did you first
4 meet ? 4 meet
5 MR. PAGLIUCA: Object to the form

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6 and foundation. 7 A. I have no idea when I met her. 8 Q. Do you know how old she was when 9 you met her? 10 A. I have no idea how old she was when 11 I met her. 12 Q. Is it possible she was 13 years old 13 when you first met her? 14 MR. PAGLIUCA: Object to the form 15 and foundation. 16 A. was Jeffrey's friend 17 and her mother was Jeffrey's friend, so 18 may have been in the house when Jeffrey was 19 in the house. I have no idea how old she 20 was. 21 Q. I understand she was with her 22 mother. 23 I'm asking if was 13 24 years old when you first met her? 25 A. I have no idea.

Q. Was she under 18 when you first met

3 her? 4 A. I have no idea how old she was when 4 A. I have no idea how old she was when 5 I first met her. 5 I first met her. 6 Q. Did she look like a child when you 7 first met her? 7 first met her? 8 A. I don't remember what she looked 9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I 12 saw her.

## p. 225

Q. How many teenagers did he have that

- 16 were professional masseuses that worked in

- 17 his home?

- 18 MR. PAGLIUCA: Objection to the

- 19 form and foundation.

- 20 Q. How many?

- 21 A. First of all, I am not aware of

- 22 teenagers who worked in his home.

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## pp. 250-251

Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any. Q. Were there any 16 year year old 3 masseuse that you are aware of? 4 A. I am not aware. 5 Q. Any 15? 6 A. I just want to be clear. The only 7 person that I am aware of who claims to have 8 been a -- we have to -- we established 9 now is 17, given she has changed her 10 age so many times. The only person that I am 11 aware of that was a masseuse at the time when 12 I was present in the house was

## pp. 253-254

Q. Did Jeffrey Epstein have a scheme Q. Did Jeffrey Epstein have a scheme

- 2 to recruit underage girls for sexual 2 to recruit underage girls for sexual

- 3 massages?

- 4 MR. PAGLIUCA: Objection to the

- 5 form and foundation.

- 6 Q. If you know. 6 Q. If you know.

- 7 A. I don't know what you are talking 7 A. I don't know what you are talking 8 about.

## p.382

Q. Can you list for me all the girls

- 5 that you have met and brought to Jeffrey

- 6 Epstein's house that were under the age of

7 18?

- 8 MR. PAGLIUCA: Objection to the

- 9 form and foundation.

- 10 A. I could only recall my family

- 11 members that were there and I could not make

- 12 a list of anyone else because that list -- it

- 13 never happened that I can think of.

## p.384

Q. List all the people under the age 16 of 18 that you interacted with at any of 17 Jeffrey's properties?

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18 A. I'm not aware of anybody that I 19 interacted with, other than obviously 20 who was 17 at this point?

## 7/22/16 Deposition

<table><tr><th>p. 70</th></tr><tr><td>Q. Did Mr. Epstein ever ask you to</td></tr><tr><td>7 attempt to obtain or secure people to give</td></tr><tr><td>8 him massages that were not professional</td></tr><tr><td>9 masseuses?</td></tr><tr><td>10 A. No.</td></tr><tr><td>p.88-89 </td></tr><tr><td>Q. Were you aware of the presence of</td></tr><tr><td>10 sex toys or devices used in sexual activities</td></tr><tr><td>11 in Mr. Epstein's Palm Beach house?</td></tr><tr><td>12 MR. PAGLIUCA: Objection to form</td></tr><tr><td>13 and foundation.</td></tr><tr><td>14 A. No, not that I recall.</td></tr><tr><td>15 Q. Were you aware that there were sex</td></tr><tr><td>16 toys or devices used in sexual activities in</td></tr><tr><td>17 Mr. Epstein's New York house?</td></tr><tr><td>18 A. No.</td></tr><tr><td>19 Q. Were you aware that there were sex</td></tr><tr><td>20 toys or devices used in sexual activities in</td></tr><tr><td>21 Mr. Epstein's property in the Virgin Islands?</td></tr><tr><td>22 MR. PAGLIUCA: Objection to form</td></tr><tr><td>23 and foundation.</td></tr><tr><td>24 A. No.</td></tr><tr><td>25 Q. Were you aware whether or not there</td></tr><tr><td>2 were sex toys or devices used in sexual</td></tr><tr><td>3 activities in Mr. Epstein's property in the</td></tr><tr><td>4 Virgin Islands?</td></tr><tr><td>5 MR. PAGLIUCA: Objection to form</td></tr><tr><td>6 and foundation.</td></tr><tr><td>7 A. No.</td></tr><tr><td>8 Q. Do you know whether Mr. Epstein</td></tr><tr><td>9 possessed sex toys or devices used in sexual</td></tr><tr><td>10 activities?</td></tr><tr><td>11 MR. PAGLIUCA: Objection to form</td></tr><tr><td>12 and foundation.</td></tr><tr><td>13 A. No.</td></tr></table>

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p. 91

15 Q. At any time, in any of Mr. 16 Epstein's properties, did you engage in 17 sexual activities with any woman other than 18 when you had three-way sexual activities with 19 Mr. Epstein? 20 MR. PAGLIUCA: Same objection. 21 A. No.

P.92

Q. I want to be sure that I'm clear. 9 Is it your testimony that in the 1990s and 10 2000s, you were not aware that Mr. Epstein 11 was having sexual activities with anyone 12 other than yourself and the blond and 13 brunette on those few occasions when they 14 were involved with you? 15 A. That is my testimony, that is 16 correct.

p. 113 p. 113

Q. You never gave a 
10 massage is your testimony?
11 A. I never gave
12 massage.

a

p.142

Q. Did you ever have conversations Q. Did you ever have conversations

- 11 with anyone that were intended to convince

- 12 them to engage in sexual activities with

- 13 Mr. Epstein?

- 14 MR. PAGLIUCA: Objection to form

- 15 and foundation. This has been asked and

- 16 answered in her previous deposition, by

- 17 the way.

- 18 A. No.

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