# 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 5 MR. PAGLIUCA: Object to the form

EFTA00010502

# Potential Perjury by Maxwell (cont.)

## P. 27 (cont.)

- 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 5 I first met her.

- 6 Q. Did she look like a child when you

- 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.

EFTA00010503

# Potential Perjury by Maxwell (cont.)

## P. 27 (cont.)

- 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

- 2 to recruit underage girls for sexual

- 3 massages?

- 4 MR. PAGLIUCA: Objection to the

- 5 form and foundation.

- 6 Q. If you know.

- 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?

EFTA00010504

# Potential Perjury by Maxwell (cont.)

## P. 27 (cont.)

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

p. 70

Q. Did Mr. Epstein ever ask you to

- 7 attempt to obtain or secure people to give

- 8 him massages that were not professional

- 9 masseuses?

- 10 A. No.

- p.88-89

Q. Were you aware of the presence of

- 10 sex toys or devices used in sexual activities

- 11 in Mr. Epstein's Palm Beach house?

- 12 MR. PAGLIUCA: Objection to form

- 13 and foundation.

- 14 A. No, not that I recall.

- 15 Q. Were you aware that there were sex

- 16 toys or devices used in sexual activities in

- 17 Mr. Epstein's New York house?

- 18 A. No.

- 19 Q. Were you aware that there were sex

- 20 toys or devices used in sexual activities in

- 21 Mr. Epstein's property in the Virgin Islands?

- 22 MR. PAGLIUCA: Objection to form

- 23 and foundation.

- 24 A. No.

- 25 Q. Were you aware whether or not there

- 2 were sex toys or devices used in sexual

- 3 activities in Mr. Epstein's property in the 4 Virgin Islands?

- 5 MR. PAGLIUCA: Objection to form

- 6 and foundation.

- 7 A. No.

- 8 Q. Do you know whether Mr. Epstein 9 possessed sex toys or devices used in sexual 10 activities?

- 11 MR. PAGLIUCA: Objection to form

- 12 and foundation.

- 13 A. No.

EFTA00010505

# Potential Perjury by Maxwell (cont.)

## 7/22/16 Deposition (cont.)

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

Q. You never gave

a

a

- 10 massage is your testimony?

- 11 A. I never gave

- 12 massage.

- p.142

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.

EFTA00010506