Ghislaine Maxwell - REDACTED PARTS CAN BY COPY/PASTA TO READ
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
https://www.courtlistener.com/recap/gov.uscourts.nysd.447706/gov.uscourts.nysd.447706.143.0_2.pdf
Q. Have you ever given Jeffrey Epstein a massage?
MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, I'm going to instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition. MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions. MR. PAGLIUCA: I disagree and you understand the bounds that I put on it. MS. McCAWLEY: No, I don't. I will continue to ask my questions and you can continue to make your objections.
Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female?
MR. PAGLIUCA: Objection. Do not answer that question. Again, to tconnection with this case I don't have any problem with you asking that question. To the extent these questions involve consensual acts between adults, frankly, they're none of your business and I will instruct the witness not to answer. MS. McCAWLEY: This case involves sexual trafficking, sexual abuse, questions about her having interactions with other females is relevant to this case. She needs to answer these questions. MR. PAGLIUCA: I'm instructing her not to answer. MS. McCAWLEY: Then we will be back here again