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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 th
ine 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
u 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
at this point? 7/22/16 Deposition p. 70 Q. Did Mr. Epstein ever ask you to 7 attempt to obtain or secure pe
ly 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 th
Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than , and therefore that her answer was false. And even if the d
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t
sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A. No. not that I recall. q
early was a masseuse aged 17 but that's, at least that's how far we know that I can think of that fulfilled any professional capacity for Jeffrey. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, oth
, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article described th
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than and therefore that her answer was false. And even if the def
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). 'ounsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t
, the following colloquy occurred: When you and Mr. Epstein were engaged in sexual activity that included th
early was a masseuse aged 17 but that's, at least that's how far we know that I can think of that fulfilled any professional capacity for Jeffrey. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, oth
Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th
early was a masseuse aged 17 but that's, at least that's how far we know that I can think of that fulfilled any professional capacity for Jeffrey. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, oth
Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th
early was a masseuse aged 17 but that's, at least that's how far we know that I can think of that fulfilled any professional capacity for Jeffrey. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, oth
2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article descri
underage girls that the defendant met and brought to Epstein. Specifically: Q. Can you list for me all the girls that you have met and brought to Jeffrey Epstein's house that were under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. I could only recall my family members that were there a
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex
early was a masseuse aged 17 but that's, at least that's how far we know that I can think of that fulfilled any professional capacity for Jeffrey. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? 126 EFTA00095218 A. I'm not aware of anybody that I
Entities connected to both Jeffrey Epstein and Q. List

Ghislaine Maxwell
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bill Richardson
PERSON
Palm Beach
LOCATION
Scarlett Johansson
PERSONDoug Band
PERSON
Michael Jackson
PERSON
David Boies
PERSON
Milan
LOCATION
Colorado
LOCATION
Southern District of New York
ORGANIZATION