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 parties: Plaintiffs [NAMES REDACTED]; Defendants: City of New York and [NAME REDACTED] (multiple blacked-out redactions visible)
- Index No.: 159225/2010
- Location: New York, New York
- Date & time: April 9, 2019 — 10:07 a.m. (highlighted)
- Proceeding: Examination before trial of the defendant; deposition taken by [NAME REDACTED], before a Notary Public of the State of New York
- Additional noted text (highlighted): "pursuant to Order and Stipulations between Counsel"

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

EFTA00011366

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

EFTA00011367

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 points from the image:

*   The speaker doesn't recall where they paid from.
*   The speaker stated that they were the only one who did any work for Ellmax.
*   Someone, likely a personal assistant, was able to do something.

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 shows an excerpt from a deposition of Ghislaine Maxwell. Key points include:
*   Maxwell confirmed someone was her personal assistant.
*   The assistant did not live with Maxwell.
*   The job was full-time.
*   Communication methods used were email, text, or phone.

Page 25: Darren Indyke helped Maxwell create Ellmax

EFTA00011371

Page 25
April 9, 2019

- Document: Transcript header "GHISLAINE MAXWELL" (Page 31 — Miami Beach address in 2014).  
- Redaction: Part of an address is blacked out after "at" (then "New York, New York").  

Key Q&A (highlights indicated):
- Q: "Could you tell me who Darren Indyke, Esq. at [redacted] New York, New York is? Could you tell me who he is?"  
  A: "He is a lawyer."  
- Q: "What is his connection with the LLC?"  
  A (highlighted): "He helped create it."  
- Q: "Did you hire him to create it?"  
  A: "I don't recall how it went down exactly. How he came to do it. But, he was the lawyer. And he helped create it."  
- Q: "Was he referred to you by somebody?"  
  A (highlighted): "He worked for a friend of mine."  
- Q: "Who is that?"  
  A (highlighted): "A gentlemen called Mr. Epstein."

Page 31(Miami Beach address in 2014)

- Document: deposition transcript excerpt (redacted).
- Location referenced: [redacted address], Miami Beach, Florida 33139.
- Q/A summary:
  - Q: What is the address at [redacted], Miami Beach, Florida 33139?
  - A: It was a home 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.
  - Q: Was it in the year 2014?
  - A: I honestly don't remember.
- Additional context (from surrounding pages): Page 31 notes Miami Beach address possibly in 2014; Page 32 notes 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

| Speaker | Text |
|---|---|
| Document header | [NAME REDACTED] |
| A | No. |
| Q | Who lived in [REDACTED] on September 9, 2015? |
| A | Excuse me? |
| Q | Are you married? (highlighted) |
| A | I was not married at the time of this. (highlighted) |
| Q | Do you have any children? |
| A | No. |
| Q | Did you have any help that lived in the house with you? |
| A | No. |
| Q | Did you have a housekeeper? |
| A | I did have a housekeeper, yes. |
| Q | Live out or live in? |
| A | Out. |

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

The image shows a transcript of a Q&A related to computers in an office.
Key information:
*   A computer existed in the office.
*   It might have been a Mack.
*   Possibly a desktop, or a laptop.
*   The individual questioned believed they owned a laptop in 2015.

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

- Line number: 25 (left margin)
- Transcript text (answer): "A. These are just all directors and none of" (truncated)
- Footer: "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

*   Contracting Employees (2015, Terramar Project, Inc.): Yes
*   Employee Name: Robert Foos
*   Position: Director of Development
*   Working 60 hours/week (2013, Terramar Project): Yes

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

The image presents a question in a legal context regarding an accountant named Mark and the accounting firm Paneth & Shron, LLP, located in New York, NY 100017. The question references a Plaintiff's Exhibit. The document is produced by 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

Q: When it was purchased in 2000, do you recall if you purchased it using [REDACTED] LLC.?
A: I believe I did.

Q: Were you the sole member of [REDACTED] LLC.?
A: Yes.

Q: Were you advised either by a lawyer or an accountant to purchase the home through an LLC?
A: I don't recall, but I'm sure I was.

Key entities:
- Property purchased in 2000
- Deed/titling: [REDACTED] LLC
- Respondent: sole member of [REDACTED] LLC
- Advice from lawyer/accountant: uncertain but likely

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

- Document type: deposition transcript fragment
- Court reporter: DEITZ Court Reporting — A Lexitas Company
- Phone: 800-678-0366
- Page number: 25 (left margin)
- Visible transcript 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 of 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

DEITZ Court Reporting — A Lexitas Company; 800-678-0166

Transcript excerpt:
Q. Did you attend the closing when you sold the building at [REDACTED]?
A. No.

Q. Did you authorize somebody to attend the closing for you?
A. Yes.

Q. Who was that?

Notes: First question and the building location are highlighted (yellow); the building location is blacked out/redacted.

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

- Document: court transcript (DEITZ Court Reporting — A Lexitas Company; 800-678-0166)
- Clerk stamp: YORK COUNTY CLERK 03/05/2020 12:59 PM; RECEIVED NYSCEF: 03/05/; INDEX NO. 159224/; Page 77
- Transcript date: April 9, 2019
- Deponent/heading: GHISLAINE MAXWELL
- Extracted Q/A snippet:
  - A: "The lawyer that is on that. I don't remember his name. Monte Albers De Leon."
  - Q: "Who is he? Is he your lawyer?"
  - A: "He was a lawyer that I used."

*   **Name:** Sandra Perkins Borger
*   **Title:** Case Manager
*   **Organization:** BOIES SCHILLER FLEXNER LLP

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EFTA00011383