EFTA00090970

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 
7 
5 MR. PAGLIUCA: Object to the form 
EFTA00090970

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 
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. 
EFTA00090971

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? 
EFTA00090972

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. 
EFTA00090973

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 
10 massage is your testimony? 
11 A. I never gave 
12 massage. 
a 
a 
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. 
EFTA00090974