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I'm not sure if they were girlfriends. I don't know what their relationship was. Q. Who are those people? A. Well, there was a (Glynn) Ghislaine Maxwell. Q. How do you know Ghislaine Maxwell? A. I met her through my brother. Q. How many times have you been around or hung out with Ghislaine Maxwell
rlfriends. I don't know what their relationship was. Q. Who are those people? A. Well, there was a (Glynn) Ghislaine Maxwell. Q. How do you know Ghislaine Maxwell? A. I met her through my brother. Q. How many times have you been around or hung out with Ghislaine Maxwell? A. Maybe a dozen or so, but we met
their ages. Q. Did you know these girls, or were these girls that were familiar with your brother? A. I didn't know them. I mean, unless it was Ghislaine or Eva years ago, but otherwise I didn't know them. Q. But the specific girls I'm talking about are the girls you are not going to speculate on t
ey Epstein after he started a relationship with Ms. Maxwell? MR. CRITTON: Form. A. I didn't spend a lot of
you ever hear that she helped to bring young girls to him for sex? A. I read that somewhere in one of the articles. Q. Is that something, knowing Ghislaine • ESQUIRE "A. ...... Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquire
in September 21, 2009 • • 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 APPEARANCES (continued) RICHARD H. WILLITS, ESQ. Attorney for Plaintiff, 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 (via telephone) BURMAN, CRITTON, LUTTIER & COLEMAN, LL
say is a frequent flyer? A. Q. A. Yes. Q. Anybody else? A. Q. A. Yeah. Q. Okay. Anybody else? A. Just mainly those two. Q. How about Ghislaine Maxwell? A. Not for some time. 3527-003 Page 60 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009735 EFTA00159542 Lar
e routinely in the last five to ten years, right? A. Yes. Q. Prior to that time, anybody that you've noticed as Jeffrey Epstein's friend may be Ghislaine Maxwell? A. What time frame? Q. Is that a person that at some point in time 3527-003 Page 71 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
in the last five to ten years, right? A. Yes. Q. Prior to that time, anybody that you've noticed as Jeffrey Epstein's friend may be Ghislaine Maxwell? A. What time frame? Q. Is that a person that at some point in time 3527-003 Page 71 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10
CRITTON: Sorry. BY MR. EDWARDS: Q. Like on this flight, we have "JE." I'm assuming that's Jeffrey Epstein, correct? A. Yes, I'll assume. Q. "GM," Ghislaine Maxwell, right? A. Yes. Q. , A. I would assume. Q. I mean -- okay. And then this name, do you recognize that person, A. Never
Pembroke Pines, Florida 33028 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 3527-003 Page 2 of 227 SUBJECT TO
ct after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house.
s room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q.
's -- Dr. Eva 3 Anderson was no longer Mr. Epstein's girlfriend, -- 4 A. That's correct. 5 Q. -- and a new girlfriend came in and that was 6 Ghislaine Maxwell? 7 A. That's correct. 8 Q. And when Ms. Maxwell came in, she, in essence, 9 took over as your immediate supervisor? 10 A. That's correct.
your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy so
RGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 ' 461 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Mi
ct after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house.
s room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q.
's -- Dr. Eva 3 Anderson was no longer Mr. Epstein's girlfriend, -- 4 A. That's correct. 5 Q. -- and a new girlfriend came in and that was 6 Ghislaine Maxwell? 7 A. That's correct. 8 Q. And when Ms. Maxwell came in, she, in essence, 9 took over as your immediate supervisor? 10 A. That's correct.
your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy so
ownsend (401 300cel-c.860-091-801.banbcaelPde EFTA00181630 Page 82 1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 5 Phone: 6 7 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 8
Entities connected to both Ghislaine Maxwell and RICHARD H. WILLITS

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONDoug Band
PERSON