From: Si 'd McCawle To: Subject: Date: Attachments: Inline-Images: FW: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version) Mon, 23 Mar 2020 21:28:16 +0000 Maxwell_Dep._Tr._(Slip_and_Fall_Case).pdf image009.png; image022.png; image037.png; image064.png; image008.png; image001jpg; image002.jpg; image003.jpg; image004.jpg; image005.jpg; image006.jpg; image007.jpg; image010.jpg; image01 1.jpg; image012.jpg; image013.jpg; image014.jpg; image015.jpg; image016.jpg; image017.jpg; image018.jpg; image019.jpg; image020.jpg; image021.jpg; image023.jpg my paralegal found this. Not sure if you have it so I wanted to pass it along. It's a 2019 depo of Maxwell in a slip and fall case in NYC. There are some clips below and the full version is attached. Best, Sigrid Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP on au er ae. From: Sandra Perkins Sent: Monday, March 23 2020 5:13 PM To: Sigrid McCawley Sabina Mariella Subject: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version) Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version) Note the File # has an AIG PRIV prefix (this has to mean that AIG is her insurance carrier on this case). CUOMO, LLC. Attorney for Defendant Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGFRIV 17007 EFTA00011365

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SHELDON BARR and THOMAS GARDNER, -against- CITY OF NEW YORK and Plaintiffs, Defendants, INDEX NO.: 159225/2010 New York, New York April 9, 2019 10:07 a.m. EXAMINATION BEFORE TRIAL of the Defendant, by GNISLAINE MAXWELL, iN the above-entitled action, held at the above time and place, taken before a Notary Public of the State of New York, pursuant to Order and Stipulations r Page 9 (Primary residence as of 9/2015 NY) EFTA00011366

Q. What was your primary residence back in September A. of 2015? Q• Can you tell me how much time you spent there, say, back in 2015 from January 1st through September 9, 2015? A. A lot of time. I lived there. That's my primary residence. Page 10 (Maxwell is a US Citizen as well as citizen of France and England) Q. A. Where were you born? Paris, France. Q. What is your date of birth? A. Q. Are you a U.S. Citizen at this time? A. Yes. Q. When did you become a U.S. Citizen? A. I don't recall. But it was some time in late ftember. '90s, mid '90s. I'm not sure. I don't Q. Are you a citizen of any other country? A. Yes. 0. What other countries? A. France and England. Page 11 Education and Licenses EFTA00011367

Q. Do you have any professional degrees or licenses? A. I do. Q. In what? A. I'm a registered emergency technician, first responder, EMT. I'm a helicopter pilot. Q. Sorry? A. Helicopter pilot. Q• Is your certification as an EMT in the United States or another country? A. In the U.S. Page 12 - Ellmax 11 12 13 14 17 18 19 20 21 22 23 Q. What is Ellmax? A. It's no longer in existence. Q. What was it? A. It was a company I started to advise othe: businesses on board placement, placing board of directors, and any other questions they might have, conferences, locations for conferences, speakers at conferences. Q. What is the primary business? Is it Ellmax, LLC.? A. I think so. Q. Is that a Florida Limited Liability Company? A. Whatever paperwork I have. I don't recal_. Whatever it says on the paperwork. EFTA00011368

Page 16 — Maxwell paid (Proof of payments?) personal assistant for more than 10 years (beginning 2001 or 2002) and herself not through Ellmax. Q. - A. GHISLAINE MAXWELL. my personal assistant. Q. How long was your personal assistant? A. More than ten years. Q. More than ten years from today? A. No. ■ doesn't work for me anymore. Q. When did you start working for you? A. Again, some time .n 2001, 2002. Something like that. Q. Was your personal assistant for the next ten years? A. Yeah. Q. Was paid by Ellmax, miLC.? A. I paid myself. Q. Did you pay out of a different company or different funds or what source? A. t don't recall where T paid from exactly. was not an employee of -- I was the only person that did any work for El:rax. Was my personal assintart. was abl•> would do Page 18 (Ellmax Florida Corporation — Maxwell stated that she lived in number of place in Florida) EFTA00011369

9 C. Was there a reason you chose a Florida 10 ILmited Liability Company for Ellmax, LAC.? 11 A. I don't know why. I don't remember. 12 Q. Were you also a Florida resident back in 13 2016? 14 A. 1 lived in Florida at certain times since 2 15 -2ved to the states. IC. 2. What is your address In Florida? A. 7 lived in a number of different places in IR 'lorida. 19 Q. Do you own real estate in Florida? 2C A. No. 21 Q. At any point did you maintain a residence 22 _n Florida? 23 A. I've never owned a home in Florida. 24 u. Dad you rent the sane residence in Florida? 2S A. No. Page 23 (Communicated with her personal assistant via email, text or phone) Where are the records? EFTA00011370

1 2 3 4 5 6 7 8 in .2 you GHTSLAINE MAXWELL Q. You said ■ was your personal assistant . A. I did. Q. Was that a remote job or did lave with or lived nearby? A. never lived in my none. I can't recall. Wherever lived I don't know. I'm .orry. Q. Was it a full-time or part-time 'oh? A. It was full-time. D. How would you communicate with Page 25: Darren Indyke helped Maxwell create Ellmax EFTA00011371

April 9, 2019 2 3 4 S 6 IJ 11 12 13 14 15 16 17 a GHISLAINE MAXWELL Q. Was there ever any other members? A. 1 don't believe so. Q. Could you tell me who Darren Indyke, Esq. New York. New York is? Could you tell me who he is? A. He is a :awyer. O. What :r his connection with the LLC? A. Me helped create tt. Q. Did you hire him to create it? A. I don't recall how tt went down exactly. How he came to do it. But, he was the lawyer. Aryl •.a helped create tt. Q. Was he referred to you by somebody? A. Ho worked tor a friend of mine. Q. Who is that? A. A gent:Almon called Mr. Spinel:— Page 31 (Miami Beach address in 2014) 11 12 13 14 15 16 What is the address at Miami Seach, Florida 33139? A. That was a home that i rented !or a short while, and I stayed at the address. 0. When did you rent it? A. I don't rota:: tne dates. 1 am sorry. 0. Was it in the year 2014. A. I honestly don't remember. Page 32 (Douglas Elliman was broker for sale of NY home) EFTA00011372

:1 12 13 14 15 16 17 lE :9 20 21 22 23 24 Q. Was that based on your accountant or a legal advise or on your own? A. I'm sure that was based on legal advise. Q. you? Did you have a lawyer that formed it for A. You are asking things to go hack over 20 years. I don't recall exactly how it went. down. Q. Did you utilize the services of a broker purchasing A. I don't remember. Q. Did you ut I re the services of a broke•( when se:ling A. 1 did. D. Was that Douglas Elliman? A. It was. Page 40 (Odd that she says not married at the time ... could she be married now)? EFTA00011373

1 2 3 April 9, GHISLAINE A. No. Q. Who lived in MAXWELL Or. 4 September 9, 2015? 5 A. Excuse me? 6 Q. Are you married? 7 A. I was not married at the time of this. 8 Q. Do you have any chi:dren? 9 A. No. 10 Q. Did you have any help that lived in the 11 house with you? 12 A. No. 13 Q. Did you have a housekeeper? 14 A. I did have a housekeeper, yes. 15 Q. Live out or live in? 16 A. Out. Page 47 (says she used a MAC or laptop in 2015) (for ESI) 15 16 17 18 19 70 2: 22 23 24 Q. Were thorn computers kept in that office? A. There was a computer in that office. Q. What kind of computer was it? A. I think it was a Hock. O. Was it • laptop or desktop? A. I think it was • desk top. It could :olive boon a laptop. I don't know. Q. Who owned that desktop? A. Well, If it was a desk top it would have been me. Actually I think it was laptop an 201',. Q. back in September of 2015, was there a desk 2019 EFTA00011374

Maxwell had a filing cabinet (hard copy records) I didn't have oustnoss recoros. C. Where did you keep the records for Ellhax. A. I use to move my : had a file cabinet wherever I was sitting. 1 had a filing cabinet. Q• Where would that be kept? Cn what floor 1 - the building? A. It moved. I frequently moved riy desk. couldn't decide where I woulc sit. Tnere was a period of time in the dining room became a place where I would sit and the library. When I moved ny desk my little filing system cop come with me. Page 52-53 (Tax returns reflect Maxwell claiming to work 60 hour weeks for Terramar) EFTA00011375

IS 16 17 18 19 20 21 22 23 24 25 Q. Referring to the bottom portion next to the yellow label of Plaintiff's Exhibit 10. Directing your attention to Page S of the tax return. Do you see this page? A. I do. 0. Did you indicate in this tax return that you worked 60 hours a week A. Yes. n the terramar Project? C. Did you have other officers at that time that worked for the Terramar Project? A. Well. done 23 hours. 08172 Court KeportIng... A LexItas Company S00-678-0166 YORK COUNTY CLERK 03/05/2020 12:59 PR IMMIX NO. RECEIVED NYSCEP: ?age 53 April 9, 2019 159224/3016 03/05/3020 113 1 2 3 QMISLAINE MAXWELL Q. Is that accurate? A. I'm ours it is. Page 54-55 Claims only "contract contractors" who paid for work — but she and other board members did not receive compensation. EFTA00011376

25 A. These aro just all directors and none of DFITZ Court Reporting... A Lexitas Company 803-678-0166 YORK COUNTY CLERK 03/05/2020 12:59 P$ . 113 2 3 4 5 B INDEX NO. 159224/201G RECEIVED ?NEGEV: 03/05/2020 Page 55 April 9, 20:9 GRISLAINE MAXWEtt cher. were :enumerated. Nobody was paid. But, Terramar Project did have work called contract contractors who did do work for it. A contract employee or contract person that worked for tne company is not the same as a regular employee. The.: wouldn't come to work. O. Who was that? A. I have had a number of -- I had a number of different people. We also have one person who did work for Terramar Project. They were always ()trait*, beCadae they would never come to work. They would be remote. Page 55: Robert Foos was a contracted employee for Terramar (Director of Development) Who paid him? EFTA00011377

14 15 16 17 16 21 22 21 74 25 0. Were there any contracting employees back in 2015 for Terramar Prolocc, Inc.? A. There were, yes. Q. Who were they? A. One. I believe It was Robert Foos. D. In what position did he hold? A. I think his official title was Director Covelopment. 0. Coos the additiona_ data sheet indicate that you were also working 60 hours a week for Terramar Project back in 2013? A. Yes. DEITZ Court Report1mg... A Lexitas Company 800-6/8-0166 YORK COUNTY crairanvomunxis-tng INDEX NO. 259224/2016 RECRIVED NTSCRF: 03/05/2020 ?age 56 April 9, 20:9 GH1SLAINE Page 57-58 (Mark, Paneth & Shron prepared her taxes for Terramar) EFTA00011378

23 Q. Was tne 24 Paneth c Shron, 25 New York 130017, accountant that prepared it Mark, LLP., New York, as indicated on Plaintiff's Exhibit DEITZ Court Reporting... A Lexitas Company 800-678-0166 YORK COUNTY CLERIC 61/015/2020 12:59 P$ 113 1 2 10? 3 A. 4 Q. 5 A. 6 Q. returns 8 Project? INDEX NO. RECEIVED NYSCEF: Page 58 April 9, 2319 CHISLAINE MAXWELL It may have been. Were they your accountants? They were. Do they always tile your personal tax and the tax returns for the Terramar Page 66 (Discussed deed being titled as 15 16 :7 Q. When it was purchased in recall if you purchased it using LLC.? 2000, do you 18 A. I believe I did. 19 Q. Were you the sole member of 20 LLC.? 21 A. Yes. 22 Q. Were you advised either by a lawyer or an 23 accountant to purchase the home through an LLC? 24 A. I don't recall, but I'm sure I was. Page 70 EFTA00011379

NO. 113 RECEIVED NYSCEF: Page 7C April 9, 2019 1 GHISLATNE MAXWELL 2 Q. When in town is that where you would sleep? 3 A. Yes. 4 Q. You had your master bedroom in the house at 5 6 A. Yes. 8 O. 2016? That was all the time between 2000 thru 9 A. Yes. 10 Q. With respect to the Terramar Project, did 11 you ever collect or have you ever collected any 12 salary as the president of the Terramar Project? 13 A. No. Page 73-74 14 15 Q. Have you received any kind from the Terramar Project remaavrat ion of uny for your servic'• for 16 that not-for-profit entity? 17 A. No. 18 Q. Is there any place in the home, at 19 that is set aside for use solely by the 20 Terramar Protect? 21 A. No. 03/05/2020 EFTA00011380

25 C. When you worked for a particular company, DEITZ Court Reporting... A Lexitas Company 800-678-0366 YORK COUNTY CLERK 03/05/2020 12:59 RI . 113 1 2 3 4 5 6 INDEX NO. 159: RECEIVED NYSCEF: 03, Page 74 April 9, 2019 GHISLAINE MAXWELL did you work with them at their premises? A. Yes. Q. DId you ever had them come to your business, to to do that work? A. No. EFTA00011381

Q. During the period of tire that Ellmax 10 11 functioned, did it generate revenue? A small amount. Q. Did you ever collect a salary for Ellmax? A. No. 12 Q. Were you ever disbursed any profits from 13 Ellmax? 14 A. No. 15 Q. What happened to the revenue that Ellmax 16 generated during that period of time, from 2010 to :7 2013? 18 A. It dust was used to deter cost such as 19 traveling and travel mostly. 20 Q. What were the costs of travel related to 21 Ellmax where you were going? 22 A. Sorry, most of the corpanies I would have 23 worked for were from Los Angeles. I went to LA and 24 also to London multiple times. Page 76-77 (Monte Albers De Leon closing lawyer for house/Maxwell did not attend closing). EFTA00011382

19 20 21 22 23 24 25 Q. Did you attend the closing when you solo the building at A. No. O. Did you authorize somebody to attend the closing for you? A. Yes. Q. Who was that? DEITZ Court Reporting... A Lexitas Company 800-678-0166 YORK COUNTY CLERK 03 . 113 /05/2020 12:59 PX 1 2 3 4 INDEX NO. 159224/: RECEIVED NYSCEF: 03/05/: Page 77 April 9, 2019 GHISLAINE MAXWELL A. The lawyer that is on that. I don't remember his name. Monte Albers De Leon. Q. Who is he? Is he your lawyer? A. He was a lawyer that I used. Sandra Perkins Borger Case Manager BOIES SCHILLER FLEXNER LLP The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections, is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. lithe reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831859 EFTA00011383