Epstein Secrets

e? 2 A. That would be privileged. 3 SPECIAL MASTER POZZUOLI: Go ahead. make 3 BY MR. EDWARDS: 4 your objection. 4 Q. Your conversation with Ghislaine Maxwell. 5 MR. INDYKE: To the extent that that 5 somebody who you have just told me you did not 6 question requires Alan to disclose privileged 6 repr

he investigation in 10 Roy Black, with two -- 10 2005 was happening. did you speak with Ghalainc 11 Q. I think we're ntiscommunicating. My 11 Maxwell?" 12 question is were you one of the attorneys that 12 MR. INDYKE: That's the question? Sorry. 13 represented Jeffrey Epstein? 13 I didn't he

ith ( autlaine Maxwell? 24 attomey-client privilege in a communication 25 MR_ SCOTT: Don't reveal any privileged 25 between Alan Dershowitz and Ghalainc Maxwell. 29 (Pages 443 to 446) www.phi sre orting.com EFTA00615832 447 449 1 THE WITNESS: Yes. there can. Would you 1 that Alan knows about only be

) goes (3) Great (1) 381:21,24 hold (1) 444:24 446:10 363:11 371:8 371:12 Harvard (1) 419:23 446:25 451:17 grounds (2) 360:19 home (2) Ghislaine (11) going (54) 363:19 450:20 Hawking (11) 348:6 360:24 421:3 422:6,23 340:5,8,9,14,25 group (1) 366:15,22 367:2 Honor (1) 427:10 444:21 34

r. but I don't know her. 20 particular — is it a violation of either the 20 BY MR. EDWARDS: 21 privilege or work product privilege who the 21 Q. Fair to say she was -- 22 particular participants arc of a joint defense 22 A. I don't think I've had a conversation with 23 agreement. if one, in fa

T SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN

vations of 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Epstein's employees, where in the hierarchy did Ms. Maxwell fall? A. Ms. Maxwell was number 2. It was definitely Mr. Epstein was a big number 1. Q. What makes you say that Ms. Maxwell was the number 2 in

1 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Tria

. Epstein's employees, where in the hierarchy did Ms. Maxwell fall? A. Ms. Maxwell was number 2. It was defin

in the early days. Might not be the case at this point, but we still tried to keep as accurate records, if we could, even if it wasn't necessary. Q. Fair enough. So but you did try to keep passenger manifests for flights on Epstein's planes? A. Absolutely, yes. Q. And a manifest, I think you describ

urveillance writing down tags and whatnot? A. No, that would have been, that would have been the Burglary Strike Force. Q. Did you ever speak with Ghislaine Maxwell? A. No. Q. Did you ever attempt to speak with her? A. No. Q. Did her name come up during your investigation? MR. PIKE: Form. THE WITNESS: I re

rike Force. Q. Did you ever speak with Ghislaine Maxwell? A. No. Q. Did you ever attempt to speak with h

urglary Strike Force. Q. Did you ever speak with Ghislaine Maxwell? A. No. Q. Did you ever attempt to spea

he 17 witness is attempting to respond. So if he has 18 a response, please less him respond and don't 19 inte.nupt him. 20 BY MR. KUVIN: 21 Q. Fair enough. I am looking for whether or 22 not you know the Statute of Limitations for the 23 prosecution fora person over 15. 24 A. I believe it's