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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
Attorneys for Plaintiffs, Jane Does 101 and 102 25 West Flagler Street, Suite 800 Miami, Florida 33130 BY: KATHERINE EZELL, ESQ. (via telephone) MERMELSTEIN & HOROWITZ, ESQS. Attorneys for Plaintiffs, Jane Does 2 through 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 BY: ADAM H. HOROWITZ, ESQ. (via
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
Palm Beach, Florida 33401 ALSO PRESENT: CARA L. HOLMES, ESQUIRE 1220 N.W. 157th Avenue 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 A
rrect? MR. YAREMA: Object to the form. A Fifth. Q This is a call from you indicating that '1= cannot work today be 1 2 3 4 5 6 7 8 48 Ghisiaine Maxwell's sexual interaction with Jane Doe-102 when she was a minor? MR. YAREMA: Object to the fonn. Q This is one of many underage minor females that was
ou 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourself, Chislalne 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numb
MR. YAREMA: Object to the font 17 Q Do you know Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in ad
L.N. and E.W. 18 425 North Andrews Avenue Suite 2 19 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 20 BY: BRADLEY J. EDWAltDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys for Plaintiffs Jane Does, numbers 2 through 8 23 18205 Biscayne Boulevard Suite 2218 24 Miami, Florida 33160 Tel: (305) 9
o answer. 8 Q. When is the last time that you talked to 9 Jeffrey Epstein? 10 A. I refuse to answer. 11 Q. Do you know a woman by the name of Ghislaine 12 Maxwell? 13 A. I refuse to answer. 14 Q. Do you know someone by the name of 16 A. I refuse to answer. 17 Q. Do you know a person named
. When is the last time that you talked to 9 Jeffrey Epstein? 10 A. I refuse to answer. 11 Q. Do you know a woman by the name of Ghislaine 12 Maxwell? 13 A. I refuse to answer. 14 Q. Do you know someone by the name of 16 A. I refuse to answer. 17 Q. Do you know a person named ? 18 A. I r
ights? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Do you know Emmy Taylor? 23 A. I refuse to answer. 24 Q. Is that somebody that is Ghislaine Maxwell's 25 sex slave? 0076 1 A. I refuse to answer. 2 Q. And isn't it typical for Jeffrey Epstein to 3 have a sex slave that flies with him on the a
N, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, Florida 33401 , ESQ. ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 EFTA00182418 18 19 20 ROBBINS, TUNKEY, ROSS, AMSEL, 21 RABEN & WAXMAN, P.A.
No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
d: March 2, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (It Bar No. 376980) MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 - 13 - EFTA00728213
ubpoenas: Nine East 71st Street Corp. Zorro Ranch, LLC JEGE, Inc., through its registered agent Corporation Trust Co. ' nter I EFTA00605572 Ghislaine, LLC, through its registered agent Corporation Trust Co. Corporation Trust Center The C.O.U.Q. Foundation, Inc. through its registered agent CT
ation System Dated: April 13, 2010 Respectfully submitted, By: /s/ Jessica D. Arbour Stuart S. Mermelstein Adam D. Horowitz Jessica D. Arbour MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 2 EFTA00605573 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy of th
Entities connected to both Ghislaine Maxwell and MERMELSTEIN & HOROWITZ

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONLeon Black
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONDoug Band
PERSONFBI
ORGANIZATIONJane Doe
PERSONEmmy Taylor
PERSONLarry Visoski
PERSON
Kenneth Marra
PERSON