EFTA01306406

FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 1:2 RECEIVEDg NYSCEF: 03/05/2020 Pa e April 9, 2019 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X SHELDON BARR and THOMAS GARDNER, Plaintiffs, -against- CITY OF NEW YORK and 116 EAST 65TH STREET, LLC, Defendants, INDEX NO.: 159225/2010 X 535 Fifth Avenue New York, New York April 9, 2019 10:07 a.m. EXAMINATION BEFORE TRIAL of the Defendant, 116 EAST 65TH STREET, LLC, by GHISLAINE MAXWELL, in the above-entitied action, held at the above time and place, taken before a Notary Public of the State of New York, pursuant to Order and Stipulations between Counsel. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323955 EFTA_0011 96640 EFTA01306406 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEI/NfblY*CEF: 03/05/2020 April 9, 2019 1 2 2 APPEARANCE S: 3 THE LAW OFFICE OF JOSEPH FALLEK 4 Attorney for Plaintiffs One Battery Park Plaza, 32nd Floor 5 New York, New York 10004 6 BY: LARRY FALLEK, ESQ. 7 8 CUOMO, LLC. Attorney for Defendant 116 EAST 65TH STREET, LLC. 200 Old Country Road, Suite 2 South Mineola, New York 11501 11 BY: MATTHEW CUOMO, ESQ. 12 FILE NO.: AIGPRIV 17007 12 IA 1( 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-676-0166 SDNY_GM_00323956 EFTA_00196641 EFTA01306407 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVIRpg@YBFEF: 03/05/2020 April 9, 2019 1 3 2 STIPULATIONS 3 IT IS HEREBY STIPULATED AND AGREED by and 4 between(among) counsel for the respective parties 5 hereto, that: 6 7 All rights provided by the C.P.L.R., 8 including the right to object to any question, 9 except as to form, or to move to strike any ID testimony at this(these) examinations(s), are 11 reserved, and, in addition, the failure to object to 12 any question or to move to strike any testimony at 13 :his(these) examination(s) shall not be a bar or 14 waiver to make such motion at, and is reserved for lb the trial of this action; 16 17 IT IS FURTHER STIPULATED AND AGREED by and 18 between(among) counsel for the respective parties 19 hereto, that this(these) examinations(s) may be 20 sworn to by the witness(es) being examined, before a 21 Notary Public other than the Notary Public before 22 whom thisithese) examination(s) was:were) begun; but 23 the failure to do so, or to return the original of 24 this(these) examinations(s) to counsel, shall not be 25 deemed a waiver of the rights provided by DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323957 EFTA 00196642 EFTA01306408 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEINWY4CEF: 03/05/2020 April 9, 2019 4 2 ST/PULATIONS (Cont'd) 3 Rules 3116 and 3117 of the C.P.L.R., and shall be 4 controlled thereby; 5 6 IT IS FURTHER STIPULATED AND AGREED by and 7 between(among) counsel for the respective parties 8 hereto, that this(these) examinations(s) may be 9 utilized for all purposes as provided by the 10 C.P.L.R; 11 12 IT IS FURTHER STIPULATED AND AGREED by and 13 between(among) counsel for the respective parties 14 hereto, that the filing and certification of the 15 original of this(these) examination(s) shall be and 16 the same hereby are waived; 17 18 IT IS FURTHER STIPULATED AND AGREED by and 19 between(among) counsel for the respective parties 20 hereto, that a copy of the within examination(s) 21 shall be furnished to counsel representing the 22 witness(es) testifying, without charge. 23 24 IT IS FURTHER STIPULATED AND AGREED by and 25 between(among) counsel for the respective parties DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323958 EFTA_00I96643 EFTA01306409 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVFERg@Y.%pEF: 03/05/2020 April 9, 2019 5 2 STI PULATIONS (Conttd) 3 hereto, that all rights provided by the C.P.L.R., 4 and Part 221 of the Uniform Rules for the Conduct of 5 Depositions, including the right to object to any 6 question, except as to form, or to move to strike 7 any testimony at this examination is reserved; and 8 in addition, the failure to object to any question 9 or to move to strike any testimony at this 10 examination shall not be a bar or waiver to make 11 such motion at, and is reserved to, the trial of 12 this action. 13 14 15 16 17 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323959 EFTA_001196644 EFTA01306410 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIXWITsCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 GHISLAINE M A X W E L L, called as a 3 witness, having been first duly sworn by a Notary Public of the State of New York, was examined and testified as follows: 6 EXAMINATION BY MR. FALLEK: 8 Q. Please state your name for the record. 9 A. Ghislaine Maxwell. 10 Q. Please state your address for the record. 11 A. 44 Kinnerton Street, London, England 12 SW183X. 13 MR. FALLEK: Good morning, Ms. Maxwell. My 14 name is Larry Fallek. I represent the 15 plaintiffs in this action, Sheldon Barr and 16 Thomas Gardner. 17 I will be asking you a series of questions 18 about an accident that occurred back on 19 September 9, 2015. Many of the questions are 20 going to involve your ownership. When I say, 21 "your ownership," I am referring to the 22 ownership of 116 East 65th Street in 23 Manhattan. 24 THE WITNESS: Okay. 25 MR. FALLEK: Before we start I have a few DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323960 EFTA_00I96645 EFTA01306411 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIligogNYSCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 basic rules I want to discuss with you. Please 3 make all your responses verbally. The Court Reporter can't take down a shake or nod of cite b head. Like you are doing right now. THE WITNESS: Of course. 7 MR. FALLEK: Please say yes or no. 6 THE WITNESS: Yes. MR. FALLEK: And try not to shrug your 10 shoulders or anything like that. Just make all 11 your response verbally. 12 THE WITNESS: I shall. 13 MR. FALLEK: Please let me finish my entire 14 question before you give an answer. The Court 15 Reporter cannot take us both down speaking a - 16 the same time. 17 Q. Is that agreeable? 18 A. Yes. 19 MR. FALLEK: It's important that you stop 20 me if you don't understand a question. If you 21 do give an answer, I will assume that you 22 understand my question. 23 0. Is that understood? 24 A. Yes. 25 0. The address that you just gave the Cot a DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323961 EFTA_00I96646 EFTA01306412 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIWOYfICEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Reporter, how long have you lived there? 3 A. '92, '93. 4 Q. Is that your primary residence at this 5 time? 6 A. No. It's just a home that I have. 7 Q. How many homes do you own back in September 8 of 2015? 9 A. Two. 10 Q. Where are those homes? 11 A. 116 East 65th Street and the one in London. 12 Q. When you say, "the one in London," you are 13 referring to the address that you just gave? 14 A. Yes. 15 Q. Is that a private home? 16 A. Yes. 17 Q. Is that home owned by you individually or 18 some other form? 19 A. It's owned by me. 20 Q. Is your name on the deed to that property 21 or the title of the property? 22 A. It was back then. I kind of -- it was up 23 until recently. I don't know. I can't remember 24 what it is now, if I changed it or not. 25 Q. Sack in September of 2015, did you or any DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323962 EFTA_00I96647 EFTA01306413 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVEWY§CEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 of your entities or companies own any other homes? 3 A. No. 4 Q. What was your primary residence back in 5 September of 2015? 6 A. 116 East 65th Street. 7 Q. Can you tell me how much time you spent 8 there, say, back in 2015 from January 1st through September 9, 2015? 10 A. A lot of time. I lived there. That's my 11 primary residence. 12 Q. Did you travel back and forth between 13 London and New York? 14 A. Extensively at. all the time. I just Gen': 15 go to London. I travel all the time to a lot of 16 different places. 17 Q. For what purposes do you travel, business, 18 pleasure, or something else? 19 A. I do business. But, it was also I work 20 on work for a not-for-profit. And I do a lot 21 of time doing conferences and a lot of speeches. 22 Q. I'm just talking about the time period of 23 January 1, 2015 through September 9, 2015. 24 Would that be true with regard to that time 25 period? DEITZ Court Reporting... A Lox tas Company 800-678-0166 SDNY_GM_00323963 EFTA_00I96648 EFTA01306414 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECElfiribNitCEF: 03/05/2020 April 9, 2019 1 GHISLA1NE MAXWELL 2 A. Correct. 3 Q. Where were you born? 4 A. Paris, France. 5 Q. What is your date of birth? 6 A. The 25th of December 1961. 7 Q. Are you a U.S. Citizen at this time? 8 A. Yes. 9 Q. When did you become a U.S. Citizen? 10 A. I don't recall. But it was some time in 11 the late '90s, mid '90s. I'm not sure. I don't 12 remember. 13 Q. Are you a citizen of any other country? 14 A. Yes 15 Q. What other countries? 16 A. France and England. 17 Q. Sorry, France and? 18 A. England. 19 Q. Are you a citizen or you are a green card 20 holder? 21 A. I'm a citizen. 22 Q. Can you tell me about your educational 23 background? What is the highest level of education 24 that you have? 25 A. I have a master's. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323964 EFTA_00I 96649 EFTA01306415 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4j INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIyne NiiCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. In what? 3 A. French and history from Oxford. It's a BA 4 MA. So when you go to oxford and you get a 5 bachelor's and some time passes and it turns into a 6 master's. 7 Q. What is the BA in? 8 A. French and history. 9 Q. It's a combined degree? IC A. Double honors degree in French and history. 11 Q. Do you have any other degrees? 12 A. No. 13 Q. Do you have any professional degrees or 14 licenses? 15 A. I do. 16 Q. In what? 17 A. I'm a registered emergency technician, 18 first responder, EMT. I'm a helicopter pilot. 19 Q. Sorry? 20 A. Helicopter pilot. 21 Q. Is your certification as an EMT in the 22 United States or another country? 23 A. In the U.S. 24 Q. You didn't offer any medical assistance to 25 :he Plaintiff in this action? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323965 EFTA_00I96650 EFTA01306416 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 1:2 RECEMyeNyICEF: 03/05/2020 April 9, 2C19 1 GHISLAINE MAXWELL 2 A. No. 3 Q. Are you presently employed? 4 A. No. S 0. Are you self-employed? A. No. Q. What was the last job that you had? A. The last job I had was at Ellmax. 9 E-L-L-M-A-X. 10 Q. What. is Ellmax? 11 A. It's no longer in existence. 12 Q. What was it? 13 A. It was a company I started to advise other 14 businesses on board placement, placing board of 15 directors, and any other questions they might have, 16 conferences, locations for conferences, speakers dt. 17 conferences. 18 Q. What is the primary business? Is it 19 Ellmax, LLC.? 20 A. I think so. 21 Q. Is that a Florida Limited Liability 22 Company? 23 A. Whatever paperwork I have. I don't recall. 24 Whatever it says on the paperwork. 25 MR. FALLEK: I'm going to show you three DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323966 EFTA_00I96651 EFTA01306417 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyireeNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 documents that we will have marked as Plaintiff's Exhibit 1, 2, 3. 4 (Whereupon, the document dated 9-18-14, 5 was received and marked as Plaintiff's Exhibit 1 6 for identification, as of this date, by the 7 reporter.) B (Whereupon, the document dated 2-23-15, 9 was received and marked as Plaintiff's Exhibit 2 10 for identification, as of this date, by the 11 reporter.) 12 (Whereupon, the document dated 3-22-16, 13 was received and marked as Plaintiff's Exhibit 3 14 for identification, as of this date, by the 15 reporter.) 16 MR. FALLEK: I'm directing your attention 17 to the document we just marked as Plaintiff's 18 Exhibit 1 for identification. 19 Q. Do you recognize this document to be the 20 2014 Florida Limited Liability Annual Report for 21 Illmax, LLC.? 22 A. I have not seen this document before so I 23 can't say that. 24 Q. Just take a look at it. 25 A. I'm looking at it, but it's the first time DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323967 EFTA )0196652 EFTA01306418 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbil INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiPVEal-De NYECEF: 03/05/2020 1 April 9, 2019 1 GHISLAINE MAXWELL 2 I've seen this. 3 Q. Did you form Ellmax, LLC.? 4 A. I did. 5 Q. Is it your company? 6 A. IL is. It was. .7 0. When was it formed? 8 A. I think 2010 or '11. 9 Q. Was it formed in Florida? 10 A. I guess. I'm sorry, I just don't recall. 11 Q. Could you tell me what the business purpose 12 of Ellmax, LLC. is? 13 A. It was a vehicle for me to be able to 14 advise companies on board of directors and to help 15 with companies for conferences and speakers for 16 their conferences. 17 Q. Board of directors of what type of 18 companies are you advising people on? 19 A. Mostly technology businesses, because I 20 know a lot of people in technology. It could be in 21 anything as a board of directors are needed in any 22 type of company. And people of good character and 23 outstanding abilities in business are always needed. 24 And I, fortunately, have a lot of friends and people 25 in that area that I will be able to place people in DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323968 EFTA_00I96653 EFTA01306419 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEigyeNlICEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 those type of companies. 3 Q. Was the principal place of business of 4 Ellmax, LLC. at 116A East 65th Street, New York, New 5 York? 6 A. It wasn't that specific. It was wherever I 7 was. Everything that is in my head is my contact, 8 my ideas. 9 Q. Specifically the document in front of you, 10 when you formed it, did you indicate that the 11 principal place of business was 116 East 65th 12 Street, New York, New York? 13 A. I think it was just filed there. It would 14 be easier for me other than any other reason. 15 0. Did you sign the documents for the limited 16 liability company known as Ellmax, LLC.? 17 A. I'm sure I did with my lawyers. There was 18 no reason other than as an address of convenience. 19 MR. FALLEK: Move to strike the 20 nonresponsive portion. 21 THE WITNESS: I'm not trying 22 NR. FALLEK: Just try focus on the question 23 that I'm asking you. 24 THE WITNESS: I'm not trying to be 25 evasive. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00323969 EFTA_00196654 EFTA01306420 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECELyneNWEF: 03/05/2020 Apri l 9, 2019 GHISLAINE MAXWELL 2 Q. Who is A. She's my personal assistant. 4 Q. How long was she your personal assistant? 5 A. More than ten years. 6 Q. More than ten years from today? A. No. She doesn't work for me anymore. 8 Q. When did you start working for you? 9 A. Again, some time in 2001, 2002. Something 10 like that. 11 Q. Was she your personal assistant for the 12 next ten years? 13 A. Yeah. 14 Q. Was she paid by Ellmax, LLC.? 15 A. I paid her myself. 16 Q. Did you pay her out of a different company 17 or different funds or what source? 18 A. I don't recall where I paid her from 19 exactly. She was not an employee of -- I was the 20 only person that did any work for Ellmax. She was 21 my personal assistant. She was able -- she would do 22 anything I would ask her to do as regards to my 23 travel, whatever. But she was -- she couldn't help 24 me with Ellmax. She didn't know people to place 25 them on board. If I directed her to get me on A DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323910 EFTA_00I96655 EFTA01306421 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIMeNISFEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 flight or something that may have been in relation 3 to business opportunity, she would do that. Q. What is her current address? S A. 1 don't know. 6 Q. Do you know what state she lives in? A. I think she's in Detroit somewhere. Q. Back in 2016, did she live at 116 East 65th 9 Street, New York, New York? 10 A. No. 11 Q. Where did she live in 2016? 12 A. Somewhere in New Jersey. 13 MR. FALLER: Directing your attention to 14 Plaintiff's Exhibit 2 for identification. 15 Q. Is that the 2015 Florida Limited Liability 16 Company for Ellmax, LLC.? 17 A. Again, I have not seen this before. I have 18 to take -- I haven't seen this before. So I'm 19 assuming that's what it is. 20 Q. Were regular annual reports filed by 21 Ellmax, LLC.? 22 A. Again, that would have been my accountant, 23 I would assume, would have a list of what is 24 expected or legally. 25 Q. Who was your accountant back then? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323971 EFTA_00I 96656 EFTA01306422 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECED F/SO aqe NYSCEF: 03/05/2020 18 April 9, 2019 GHISLAINE MAXWELL 2 A. I am sorry, I don't recall the name at this 3 moment. 4 Q. What was the name of the company that you 5 worked for? 6 A. I don't recall. I am sorry. 7 Q. Was he in New York or Florida? 8 A. In New York, I believe. 9 Q. Was there a reason you chose a Florida 10 Limited Liability Company for Ellmax, LLC.? 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. I lived in Florida at certain times since I 15 moved to the states. 16 Q. What is your address in Florida? 17 A. I lived in a number of different places in 18 Florida. 19 Q. Do you own real estate in Florida? 20 A. No. 21 Q. At any point did you maintain a residence 22 in Florida? 23 A. I've never owned a home in Florida. 24 Q. Did you rent the same residence in Florida? 25 A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323972 EFTA_00I96657 EFTA01306423 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIffeeNiiFEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. How many months of the year, let's say, it 3 2016 did you reside in Florida? 4 A. Probably none. 5 Q. How much time did you spend in Florida .L:1 6 2016? 7 A. Probably, I don't know, less than -- I S don't know. A few weeks. Two weeks, three weeks. 9 Q. What about in 2015? 10 A. I don't remember the dales. Maybe the 11 same. 12 Q. The principal place of business in 2015 is 13 still listed as 116A East 65th Street, New York, New 14 York. 15 A. That would have all been the address for 16 convenience. 17 Q. That address was never changed was it? 18 A. I don't believe so. 19 Q• Was the address of Ellmax always the same 20 from the time it was formed until up the time you 21 say you dissolved it? 22 A. As far as I can recall, yes. 23 MR. FALLEK: 1 am directing your attention 24 to Plaintiff's Exhibit 3 for identification. 25 Q. Do you recognize this document? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323973 EFTA_00I96658 EFTA01306424 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIg8eNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Sorry. 3 Q. Plaintiff's 3 for identification, do you 4 recognize this to be the 2016 Florida Limited 5 Liability Company Annual Report for Ellmax, LLC.? 6 A. Again, I have never seen this. I will just 7 take your word that that's what that is. 8 Q. In 2016, was the principal place of 9 business for Ellmax, LLC. also listed as 116 East 10 65th Street, New York, New York? 11 A. Again, that was the address of convenience. 12 The business is wherever I am, but yes. 13 MR. FALLEK: Move to strike the 14 nonresponsive portion of the answer. 15 Q. Did Ellmax, LLC. ever have a different 16 principal place of business? 17 A. I don't believe I had any other address of 18 convenience than the one it has listed. 19 MR. FALLEK: Move to strike as 20 nonresponsive. 21 Q. Is the answer no? 22 A. No. 23 Q. No it never had any other principal place 24 of business? 25 A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323974 EFTA_00196659 EFTA01306425 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyafliCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. What were the assets of Ellmax, LLC.? 3 A. it didn't have any assets. 4 Q. Who were the members of the limited 5 liability company? 6 A. I believe I was the sole member. 7 Q. Did Ellmax, LLC. have any employees? 8 A. No. Q. I believe you said the last job you had was 10 for Ellmax, LLC.? 11 A. Last work that I did as you asked. 12 Q. Before you worked for Ellmax, LLC., whom do 13 you work for? 14 A. I was unemployed. 15 Q. During what period of time was that? 16 A. I believe around 2000 -- about 2009 or '08. 17 Q• When did you first move to the United 18 States to live here continuously? 19 A. 1991. 20 Q. Where did you live in 1991? 21 A. I was traveling around the states. 22 Q. Was 116 East 65th Street, New York, New 23 York, the first residence that you had in the United 24 States? 25 MR. FALLER: You seemed confused. I will DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323975 ER-Ai/0196660 EFTA01306426 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEiyneNWEF: 03/05/2020 April 9, 2019 1 GH:SLAINE MAXWELL 2 ask it a different way. 3 Q. Where was the first place you lived in the 4 United States? 5 A. I rented. 6 Q. Where did you rent? 7 A. I rented a place on 59th and Seventh. 8 Q• Did there come a time period where you 9 purchased a residence? 10 A. Yes. 11 Q. When was that? 12 A. When I purchased 116, I believe, in 2000. 13 Q. Before 116 was purchased, did you form 116 14 East 65th Street, LLC.? 15 A. No. I don't believe so, no. 16 MR. FALLEK: Could we have this marked as 17 Plaintiff's Exhibit 4 for identification. 18 (Whereupon, the document dated 4/5/19, was 19 received and marked as Plaintiff's Exhibit 4 for 2C identification, as of this date, by the 21 reporter.) 22 Q. Before we get to this document. Was there 23 a time period in which =MI lived in 24 Manhattan? 25 A. I don't know. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323976 EFTA_00196661 EFTA01306427 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEM eNWEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. You said she was your personal assistant. 3 A. I did. 4 (2• Was that a remote job or did she live with 5 you or lived nearby? 6 A. She never lived in my home. I can't 7 recall. Wherever she lived I don't know. I'm 8 sorry. 9 Q. Was it a full-time or part-time job? 10 A. It was full-time. 11 Q. How would you communicate with her? 12 A. Via, email, text, or phone. 13 Q. During what time period, if any, did she 14 live in New York? 15 A. I don't know if she lived in New York. She 16 worked for me, and she turned up for work for me. 17 But, I don't know where she lived. 10 Q. Did you have somebody else, a different 19 personal assistant for you, in Manhattan? 20 A. No. 21 MR. FALLEK: I'm going to show you what was 22 marked as Plaintiff's Exhibit 4 for 23 identification. I ask you to take a look at 24 that document. 25 Q. Do you recognize this document to be a DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323977 EFTA 00196662 EFTA01306428 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 24 April 9, 2019 GHISLAINE MAXWELL 2 document from the New York State Department of State 3 regarding 116 East 65th Street, LLC.? 4 A. I have never seen this document before. 5 Q. Could you please take a look at it. MR. CUOMO: I think she has. 7 A. I've looked at it. 8 Q. Did you form 116 East 65th Street, LLC. 9 A. Yes. 10 Q. When was it formed? 11 A. Some time in 2000. 12 Q. Is that prior to the time that 116 East 13 65th Street was purchased? 14 A. I don't know the timing of it when it was 15 purchased. I don't know when the time was for the 16 creation of it and the purchase of the house. I'm 17 sorry. 18 Q. Is 116 East 65th Street a limited liability 19 company? 20 A. I believe so. 21 Q. Is it a New York Limited Liability Company? 22 A. I don't remember where it is limited. It 23 says, New York. 24 Q. Who are the members of that LLC? 25 A. I believe I'm the sole member. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323978 EFTA_00196663 EFTA01306429 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 25 April 9, 2019 GHISLAINE MAXWELL Q. Was there ever any other members? A. I don't believe so. 4 Q. Could you tell me who Darren Indyke, Esq. 5 at 475 West Avenue, New York, New York is? Could 6 you tell me who he is? 7 A. He is a lawyer. 8 Q. What is his connection with the LLC? 9 A. He helped create it. 10 Q. Did you hire him to create it? 11 A. I don't recall how it went down exactly. 12 How he came to do it. But, he was the lawyer. And 13 he helped create it. 14 Q. Was he referred to you by somebody? 15 A. He worked for a friend of mine. 16 Q. Who is that? 17 A. A gentlemen called Mr. Epstein. 18 Q. Sorry? 19 A. A gentleman. 20 Q. Is that Jeffrey Epstein? 21 A. Yes. 22 Q. What was the principal place of business of 23 116 East 65th Street, LLC.? 24 A. well, 116 didn't do any business. 25 Q. What was the principal place business? Do DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323979 EFTA_00I 96664 EFTA01306430 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NY9CEF: 03/05/2020 Page 26 April 9, 2019 1 GHISLAINE MAXWELL 2 you maintain books for it? 3 A. I don't have any paperwork regarding that. 4 1 don't have. It would have been with the S accountant or whoever was dealing with it then. Q. Were there annual returns that were prepared for that LLC? 8 A. I'm sure there were. 9 Q. Did you sign them? 10 A. I must have. 11 Q. Where are they? 12 A. So long ago I have no idea. I don't have 13 that. 14 Q. Did there come a time period where 116 East 15 65th Street, LLC. purchased the building at 116 East 16 65th Street, New York, New York? 17 A. I am sorry, I don't know the -- I think 18 50. 19 Q. Who owned your building? 20 A. 116 East 65th Street, LLC. 21 Q. When was it purchased by them? 22 A. Like I have said, some time in 2000. 23 MR. CUOMO: Before you ask another question 24 I just want to talk to my client for a moment. 25 (A short recess was taken.) DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323980 EFTA_00196665 EFTA01306431 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECELVED NYS_CEF: 03/05/2020 Page 2 April 9, 2019 GHISLAINE MAXWELL 2 Q. Did you review any documents today before 3 testifying? 4 A. Only what was filed with the court with my lawyer. Q. Did you read or review your affidavit 7 before testifying today? 8 A. I did review? MR. FALLEK: Mark this as Plaintiff's 10 Exhibit five. 11 (Whereupon, the affidavit was received and 12 marked as Plaintiff's Exhibit 5 for 13 identification, as of this date, by the 14 reporter.) 15 MR. FALLEK: I will show you what was 16 marked as Plaintiff's Exhibit 5 marked for 17 identification. 18 Q. I will ask if that is the affidavit that 19 you reviewed? 20 A. I'm going to read it to make sure. 21 Q. Take your time. 22 A. Is that okay? 23 Q. Sure. Did you have a chance to read it? 24 A. I have. 25 Q. In your affidavit, in Paragraph 9, you say DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323981 EFTA_00I 96666 EFTA01306432 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 28 April 9, 2019 1 GHISLAINE MAXWELI. 2 that Ellmax, LLC. was a holding company when I 3 started in 2010 with the intention of using for any 4 consultation work that I may have done. What are 5 you referring to? What consultation work that I may 6 have done? 7 A. Like I have explained earlier. I advised 8 businesses or wanted to advise businesses in 2010 on 9 placing people on boards or on any other aspect of 10 business that would be relevant, conferences, and 11 providing speakers for conferences. 12 Q. You used the words "I may have done." Was 13 that work you already had done or going to do? 14 A. That I was hoping to do. 15 Q. Were you one of the speakers or were you 16 looking for other speakers? 17 A. I have spoken, but I've never hired myselt 18 to speak. 19 Q. For Ellmax? 20 A. No. That would have been funny. 21 Q. You indicated also that you never took 22 deductions on your taxes as a home office. Did you 23 file income taxes in 2015? 24 A. I did. 25 Q. What taxes did you file in the United DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323982 EFT,k_00196667 EFTA01306433 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 April 9, 229 019 1 GHISLAINE MAXWELL 2 States? 3 A. Whatever I needed to file. 4 Q. Did you file a New York State Income Tax? 5 A. I'm sure I did. 6 Q. Did you file Federal taxes in the Unites 7 States? 8 A. I'm sure I did. 9 Q. What about City taxes? Did you also file 10 those? 11 A. I'm sure I did. 12 Q. You also indicated in Paragraph 11, in 2010 13 when I started, you had said that you hired an 14 assistant to Ellmax, LLC's payroll in 2017. Who was 15 that? 16 A. That was Dana. 17 Q. Was that the same person that we spoke 18 about before? 19 A. Yes. 20 Q. That's 21 A. Yes. 22 Q. What location did she work out of other 23 than New Jersey? 24 A. I believe her home. 25 Q. Do you know if she worked out of her home DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323983 EFTA_00196668 EFTA01306434 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 30 April 9, 2019 1 GHISLAINE MAXWELL 2 any other years? 3 A. She worked. She was on call. She would 4 have done work from her home. 5 Q. What did she do for Ellmax, LLC.? 6 A. She didn't do any work for Ellmax. She 7 worked for me. She was my personal assistant. But 8 if I asked her to make a flight or something, then 9 it would have been. 10 MR. CUOMO: Just clarify. Are you asking 11 about 2017? 12 MR. FALLEK: Yes. She said added her in 13 2017 on Ellmax's payroll. 14 Q. Why did you add her to the payroll? 15 A. I misunderstood the question. 16 To shutdown the company. We restarted it 17 start to shut it down. 18 Q. Did she work for Ellmax prior to 2017? 19 A. No. She -- whatever -- Ellmax was dormant 20 from 2013 until I restarted to shut it down. 21 MR. FALLEK: Move to strike as not 22 responsive. 23 Q. You did file annual reports, did you not, 24 in 2014, '15, and '16 for Ellmax, LLC.? 25 A. Right. But, it was just, you know, to DEITZ Court Reporting... A Lexitas Company 800-678-0166 S0NY_GM_00323964 EFTA_00196609 EFTA01306435 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NXSCEF: 03/05/2020 Page 31 April 9, 2019 GHISLAINE MAXWELL 2 keep -- rather than going through the expense t' 3 shut it down. It's expensive to shut it down. 4 Q. so the answer is: No, you did file them 5 all those year? 6 A. It was filed, but it was dormant. 7 Q. Did you have to file a fee every year? 8 A. I'm sure I did. 9 Q. What is the address at 16 Island Avenue, 10 Suite 70, Miami Beach, Florida 33139? 11 A. That was a home that I rented for a short 12 while, and I stayed at the address. 13 Q. When did you rent it? 14 A. I don't recall the dates. 1 am sorry. 15 Q. Was it in the year 2014. 16 A. I honestly don't remember. 17 MR. FALLEK: I'm showing you what was 18 marked as Plaintiff's Exhibit 1 for 19 identification, which it dates back to 2014. 20 MR. CUOMO: She said she doesn't remember. 21 A. I'm sorry, I don't recall. 22 Q. In the year 2015 the address changed, is it 23 not, to New York, New York? 24 A. It has. 25 Q. Do you know where the articles of an DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323985 EFTA_001196670 EFTA01306436 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 32 April 9, 2019 1 GHISLAINE MAXWELL 2 organization are for 116 East 65th Street, LLC.? A. I don't. 4 Q. Do you know who has them? 5 A. I don't. Q. Do you know what the business purposes was for forming 116 East 65th Street, LLC.? A. I think it's a common practice to place 9 them as an LLC. I don't think there is anything 10 unusual about that. :1 Q. Was that based on your accountant or a 12 legal advise or on your own? 13 A. I'm sure that was based on legal advise. 14 Q. Did you have a lawyer that formed it for 15 you? 16 A. You are asking things to go back over 20 17 years. I don't recall exactly how it went down. 18 Q. Did you utilize the services of a broker in 19 purchasing 116 East 65th Street? 20 A. I don't. remember. 21 Q. Did you utilize the services of a broker 22 when selling 116 East 65th Street? 23 A. 1 did. 24 Q. Was that Douglas Elliman? 25 A. It was. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323986 EFTA_00I96671 EFTA01306437 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVEDPage 3 NYSCEF: 03/05/2020 3 April 9, 2019 GHISLAINE MAXWELL 2 Q. How much did 116 East 65th Street, LLC. 3 pay for the purchase of 116 East 65th Street in 4 Manhattan? S A. Around, I think it was, $6,000,000. Around 6 6,000,000. 7 Q. Could you describe the building to me at A 116 East 65th Street? 9 A. What do you mean? 10 Q. Let's start with, how many floors did the 11 building have? 12 A. Five. 13 Q. That includes the roof and the basement? 14 A. No. I think the basement would be six. If 15 you count the roof then seven. 16 Q. What was the square footage of the 17 building? 18 A. Around 6,500 or 6000 (sic). Something like 19 that. 20 Q. How many bedrooms did it have? 21 Four. 22 Q. How many bathrooms? 23 A. Four. 24 Q. Was the lot a 25 foot wide lot? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323987 EFTA 00196672 EFTA01306438 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED Page 34 NYSCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. Was this a limestone building? 3 A. Yes. 4 Q. Did it have an elevator? 5 A. Yes. 6 0. Was there a separate entrance that the 7 building had? How many entrances did 116 East 65th 8 Street have? 9 A. Two. 10 MR. FALLEK: I will show you a document : 11 will have marked as Plaintiff's Exhibit 6. 12 (Whereupon, the copy of a photograph was 13 received and narked as Plaintiff's Exhibit 6 for 14 identification, as of this date, by the 15 reporter.) 16 Q. Do you recognize what is shown in 17 Plaintiff's Exhibit 6 for identification? 18 A. I do. 19 Q. What do you recognize that to be? 20 A. 116 East 65th Street. 21 Q. Is that the building that was purchased by 22 116 East 65th Street, LLC.? 23 A. Yes. 24 Q. Does that document or that photograph 25 fairly and accurately show the way the building DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323988 EFTA_00I96673 EFTA01306439 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVEgD NYSCEF: 03/05/2020 Pa e 35 April 9, 2019 GHISLAINE MAXWELL 2 appeared back on September 9th of 2015? 3 A. I suppose. 4 Q. Was there a tree or tree well in front of 5 your premises? 6 A. Yes. Q. Was a portion of the tree well was part ' your premises and your neighbor's premises? A. No. 10 Q. Do you recognize the metal cage surrounding 11 the tree well? 12 A. Yes. 13 Q. During the time period that 116 East 65th 14 Street owned the building, did you or anybody on 15 your behalf make any changes to the tree or the tree 16 well? 17 A. This tree well that you demonstrate here in 18 this photograph, is the tree and the tree well 19 belonging to my neighbor at 114 East 65th. 20 Q. Is a portion of that tree going on your 21 property? 22 A. I don't recall, but that's the address of 23 the tree. 24 Q. Did you ever discuss the tree or tree well 25 with your neighbor? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323989 EFTA_00I 96674 EFTA01306440 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page JO April 9, 2019 1 GHISLAINE MAXWELL 2 A. No. 3 Q. You said it's whose tree well? 4 A. Diandra. 5 Q. Diandra Douglas? 6 A. Yes. 7 Q. Did they live there before you moves 8 there? 9 A. No. 10 Q. When did they move in? 11 A. I don't recall exactly. Maybe 2005 or '06. 12 Something like that. 13 Q. At any time did you sweep the leaves from 14 that tree on that portion of the sidewalk in front 15 of your premises? 16 A. Can you repeat the question? 17 Q. Was there anytime that you lived at 116 18 East 65th street where you maintained the tree that 19 we are referring to in the photograph? 20 A. Diandra's tree? 21 Q. Yes. 22 A. No. 23 Q. Did you ever trim the branches? 24 A. No. 25 Q. Did anybody on your behalf ever water the DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323990 EFTA_00I96675 EFTA01306441 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 37 April 9, 2019 1 GHISLAINE MAXWELL 2 tree? 3 A. No. 4 Q. Did you do anything or have anyone do 5 anything around the tree well? 6 A. Around Diandra's tree? Q. Yes. 8 A. No. 9 Q. Did you ever discuss the tree with Diandra? 10 A. No. 11 Q. The sidewalk that is depicted in the 12 picture, were any changes made to that sidewalk by 13 you or anybody on your behalf during the time period 14 that 116 East 65th Street owned the premises? 15 MR. CUOMO: Hold on a second. From that 16 photograph can you tell? 17 MR. FALLEK: I'm not talking about that. 18 I'm just directing her to the sidewalk. 19 MR. CUOMO: Hear me out. I have a question 20 for you. Are you representing that all of the 21 sidewalk in that photograph depicted is Exhibit 22 6 is in front of 116 East 65th Street or are you 23 asking her part from that photograph in front of 24 116 East 65th Street? 25 MR. FALLEK: Let's first ask about the DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323991 EFTA_00I96676 EFTA01306442 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 38 April 9, 2019 GH:SLATNE MAXWELL 2 photograph. 3 Q. Was any work done by you or anybody to that area that is shown in the photograph? S A. I've never directed anybody to do any work 6 on the sidewalk. 7 Q. Did anybody do any work to the sidewalk 8 during that time period that you lived there? MR. CUOMO: Again, note my objection. Are 10 you talking about the sidewalk in front of her 11 home or the sidewalk that is in the photograph, 12 which could be in front of multiple buildings? 13 MR. FALLEK: The sidewalk in the 14 photograph. 15 A. I don't remember work being done passed me 16 on the sidewalk. But, there was work, I believe, 17 done around Diandra's tree. But, I don't know. 18 Q. What was the work done around Diandra's 19 tree? 20 A. That tree is a big tree. It has a lot of 21 roots. And I think there was some work done around 22 her tree and her tree well, but I don't recall. 23 0. Do you remember when that was? 24 A. I don't. 25 Q. Was it before September 9, 2015? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323992 EFTA_00I96677 EFTA01306443 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NY.SCEF: 03/05/2020 Page 39 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Any work would have been done around that 3 tree would have been done prior to that, yes. 4 Q. The work you are referring to, was that S done to the tree, the tree well, or the sidewalk? 6 A. 1 apologize, I just don't know. I don't 7 know. 8 Q• Besides the Diandra did anybody else live 9 in the house during that time period? 10 A. Any house? 11 Q. Diandra's house. 12 A. I don't know who lived with Diandra. 13 Q. We are referring to 114 East. 65th Street? 14 A. 114, yes. 15 Q. Did you ever talk to her about the 16 condition of the tree, the tree roots, or th. 17 sidewalks prior to September 9, 2015? 18 A. No. 19 Q. Did anybody ever complain to you about the 20 condition of the sidewalk in front of your premises 21 before September 9th of 2015? 22 A. No. 23 Q. Did you ever receive any violations from 24 the City of New York or anybody regarding the 25 condition of the sidewalk in front of your premises? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323993 EFTA_00I96678 EFTA01306444 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED 40 NYSCEF: 03/05/2020 April 9, 2019 1 GHISLAINE MAXWELL 2 A. No. 3 Q. Who lived in 116 East 65th Street on 4 September 9, 2015? A. Excuse me? Q. Are you married? A. I was not married at the time of this. 8 Q. Do you have any children? 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. 17 Q. How many days a week did she come to your 18 home? 19 A. She came every day during the week. 20 Q. That was Monday through Friday? 21 A. Correct. 22 Q. What was her name? 23 A. Maritsa. 24 MR. CUOMO: Just to be clear now, you are 25 talking about 2015? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323994 EFTA_001196679 EFTA01306445 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 41 April 9, 2019 1 GHISLAINE MAXWELL 2 MR. FALLEN: Yes, back in September of 3 2O15. 4 A. That's how I answered your question. 5 Q. Maritsa worked for you five days back then? 6 A. Yes. 7 Q. What were her duties and responsibilities? 8 A. She was my housekeeper. So she would keep 9 the house clean, and she would do the laundry. And 10 She would Hoover. She would help me cleanup in the 11 kitchen after I made a mess. 12 MR. CUOMO: I have to break in there. 13 (A discussion was held off the record.) 14 Q. Who was responsible to take care of the 15 outside of the home specifically the sidewalk in 16 front of your home? 17 A. I don't. But, I didn't designate anybody 18 to clean the sidewalk or whatever. 19 Q. Did somebody maintain the sidewalk in front 20 of the home back in 2015? 21 A. No. 22 Q. Who would sweep the sidewalks? 23 A. I don't know. 24 Q. If there was snow, who would shovel the 25 sidewalk? 0EITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323995 EFTA_001196680 EFTA01306446 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 42 April 9, 2019 1 GHTSLAINE MAXWELL 2 A. I'm not sure. 3 Q. Did you hire an outside contractor or 4 gardener or a person to maintain the exterior? 5 A. No. 6 Q. Did you enter the premises through the front door every time you went in and out? 8 A. Sometimes mostly. 0 Q. How else would you go in the house other 10 than the entrance that is shown in the photo in 11 front of you? 12 A. You could go in the other entrance. 13 Obviously, I mostly used the front entrance. 14 Q. You said there were two entrances. 15 A. Yes. 16 MR. FALLEK: Could we have this marked. 77 (Whereupon, the copy of a photograph was 18 received and marked as Plaintiff's Exhibit 7 for 19 identification, as of this date, by the 2C reporter.) 21 MR. FALLEK: 1 will show you a photograph, 22 which we marked as Plaintiff's Exhibit 7 to: 23 identification. 24 Q. Have you seen this photograph before? 25 A. I have not. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323996 EFTA_00196681 EFTA01306447 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL 2 Q. Do you recognize what is shown in that 3 photograph? 4 A. I do. But, I don't know what this bag is 5 (indicating). 6 Q• That makes two of us. 7 MR. CUOMO: Just notice the bag hanging from the door handle. G Q. Separate from the bag, do you recognize -- IC A. I do. 11 Q. Is that a door to the premises of 116 East. 12 65th Street, New York, New York? 13 A. It appears to be, yes. 14 Q. How do you refer to this entrance? Is it 15 the service entrance, business entrance? 16 A. Separate entrance. 17 Q. Where does this entrance lead? 18 A. To the house. 19 Q. Have you ever received or seen the 20 Certificate Of Occupancy? 21 A. Have I? 22 Q. Seen the Certificate Of Occupancy for the 23 house? 24 A. I don't recall seeing it. 25 Q. Is the building a two-family residence? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00323497 EFTA _00I96682 EFTA01306448 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 44 April 9, 2019 GHISLAINE MAXWELL 2 A. I believe it is valued, but I think it has 3 a designation as a two-family residence or however 4 you say that. S 0. Did you have a dog at the time that you 6 lived in the building? A. Yes. 8 0• Was that Beware Of Dog sign put up by you 9 or someone on your behalf? 10 A. 1 put it up. 11 0. Who would walk the dog when you lived there 12 back in 2015? :3 A. I walked my dog. Dana walked my dog or :4 whoever. 15 0. Did you reg.-Ile/1y walk the dog yourself? 16 A. Yes. :7 0. Is there a back entrance to the building? :8 A. NO. 19 0. :n order to walk the dog, would you have to 20 go out the front door or the side door? 21 A. You could go out either entrance. 22 Q. Would you go in and out one of those doors 23 every day? 24 A. Yes. 25 Q. Is there a buzzer or intercom system for DEIT? Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323498 EFTA_00I 96683 EFTA01306449 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 45 April 9, 2019 1 GHISLATNE MAXWELL 2 that entrance? 3 A. I don't think so. Q. What about for the front door, the door that is shown in Exhibit 6 for identification? A. There was a buzzer for that door. Q. How many buzzers were there? 8 A. Just one I think. 9 Q. Where would it buzz in the interior -- 10 A. Buzz to the telephone. 11 Q. To the telephone? 12 A. Yes. 13 Q. Where is the telephone kept? 14 A. Telephone everywhere. All the telephones 15 would go. You couldn't fail to hear the doorbell. 16 Q. Who would answer the door? Would that be 17 you or someone else? 18 A. Whoever got to it first. 19 Q. Who would that be? Would you say Maritsa? 20 A. Typically me or Dana or Maritsa, whoever. 21 Q. Were there times when Dana was in the house 22 back in September of 2015? 23 A. Yes. 24 Q. What about in August of 2015, were there 25 also times where she would be in the house? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GNL00323999 OF1A_00196524 EFTA01306450 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 46 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Yes. 3 MR. FALLEK: Could I have this marked. 4 ;Whereupon, the diagram of the house was 5 received and marked as Plaintiff's Exhibit 8 for 6 identification, as of this date, by the 7 reporter.) 8 (Whereupon, the diagram of the house was 9 received and marked as Plaintiff's Exhibit 9 for 10 identification, as of this date, by the 11 reporter.) 12 MR. FALLEK: I will show you what was 13 marked as Plaintiff's Exhibit 8. 14 Q. Do you recognize what has been marked as 15 Plaintiff's Exhibit 8 for identification? 16 A. Yes. 17 Q. When you sold the premises, 116 East 65th 18 Street, is this a diagram that was used in order to 19 sell the home? 20 A. I think it was, yes. 21 Q. Do you recognize what is depicted in that 22 diagram? 23 A. Yes. 24 Q. What is it? 25 A. It says office. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324000 EFTA_00I96685 EFTA01306451 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 47 April 9, 2019 GHISLAINE MAXWELL Q. What is here generally? A. Sorry. I Q. What is depicted in the diagram? S A. The house. 6 Q. Does it fairly and accurately show the 7 layout of the house, 116 East 65th Street? 8 A. Yes. 9 Q. Did the home have an office in it? 10 A. It was called an office. 11 Q. How big was that area labeled as an 12 office? 13 A. It says here 17.3 feet, 17 feet 3 inches x 14 8 feet 3 inches. 15 Q. Were there computers kept in that office? 16 A. There was a computer in that office. 17 Q. What kind of computer was it? 18 A. I think it was a Mack. 19 Q. Was it a laptop or desktop? 20 A. I think it was a desk top. It could have 21 been a laptop. I don't know. 22 Q. Who owned that desktop? 23 A. Well, if it was a desk top it would have 24 been me. Actually I think it was laptop in 2015. 25 Q. Back in September of 2015, was there a desk DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324001 EFTA_00I96686 EFTA01306452 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 48 April 9, 2019 1 GHISLAINE MAXWELL 2 also in that room? 3 A. Yes. 4 Q. was there a copy machine? 5 A. There may have been. 6 Q. Was there a fax machine? 7 A. No. 8 Q. What other equipment was kept in that 9 office? 10 A. No equipment. I can't remember if it was a 11 laptop or a desktop. Dana -- that's where Dana 12 generally sits. 13 Q. Was there any other office equipment kept 14 in their? 15 A. No. 16 Q. Was there a door to that room? 17 A. Yes. There was also a coffee station. 18 There was a little coffee sink, a little fridge in 19 there for access in the garden. It's like a garden 2O room. You could get a drink if you were sitting in 21 the garden back here. 22 MR. FALLEK: I will show you what was 23 marked as Plaintiff's Exhibit 9 for 24 identification. This is just a blow-up or 25 larger version of Plaintiff's Exhibit 8 for DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324002 EFTA_00I96687 EFTA01306453 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 49 April 9, 2019 GNISLAINE MAXWELL Identification. 3 Q. Does this fairly and accurately show the 4 layout of the building at 116 East 65th Street as it 5 existed back in September of 2015? 6 A. Yes. 7 Q. Was there any portions or rooms in this 6 building rented out or separated? 9 A. No. 10 Q. Was anything cordoned off? 11 A. No. 12 Q. What was kept in the basement of the 13 building? 14 A. Laundry mostly. 15 Q. What was on the roof of the building? 16 A. Nothing. AC I think. 17 Q. On the first floor there :s also a library? 16 That's what it says. 19 Q. Did you utilize that room as a library? 20 A. No. It was more like 7 use it to watch TV. 21 There was big screen in that room. 22 Q. Was there a room in that building where you 23 stored business records? 24 A. No. 25 Q. Where did you store your business records DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324003 EFTA_00I96688 EFTA01306454 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 50 April 9, 2019 1 GHISLAINE MAXWELL 2 back in 2015? 3 A. I didn't have business records. 4 Q. Where did you keep the records for Climax, 5 1. 6 A. 1 use to move my -- I had a file cabinet 7 wherever I was sitting. I had a filing cabinet. 9 Q. Where would that be kept? On what floor in 9 the building? 10 A. It moved. I frequently moved my desk. 11 couldn't decide where I would sit. There was a 12 period of time in the dining room became a place 13 where I would sit and the library. When I moved my 14 desk my little filing system cop come with me. 15 Q. Did you conduct business out of 116 East 16 65th street? 17 A. No. 18 Q. Where did you conduct any business for 19 Ellmax, LLC.? 20 A. I go to any client and I would go to their 2: office. 22 Q. Tell me about your Terramar Projects? 23 A. It's a not-for-profit based on the ocean. 24 Q. When did you form the Terramar Project? 25 A. I think it was in 2011 or 2012. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324004 EFTA_00I 96689 EFTA01306455 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 51 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. That would be have been before September 9, 3 2015? 4 A. Yes. 5 Q. Who is the president of the Terramar 6 Project, Inc.? 7 A. I am. 8 Q. Is that a New York Corporation? 9 A. I don't remember where it was filed. If 10 you have the paperwork in front of you and it says 11 New York then yes. 12 MR. FALLEK: I will show you a document 13 marked as Plaintiff's Exhibit 10. Let's mark it 14 first. 15 THE WITNESS: Could I use the bathroom? 16 MR. FALLEK: Yes. Whenever you need a 17 break just ask. 18 (Whereupon, the 2012 tax document was 19 received and marked as Plaintiff's Exhibit 10 20 for identification, as of this date, by the 21 reporter.) 22 (A short recess was taken.) 23 MR. FALLEK: I will show you what was 24 marked as Plaintiff's Exhibit 10 for 25 identification. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324005 EFTA_001196690 EFTA01306456 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 52 April 9, 2019 1 GHISLAINE MAXWELL 2 C. Do you recognize this document to be the 3 2012 tax return for Terramar? 4 A. I have not seen this. S Q. Take a look at it. 6 A. It appears to be. 7 Q. Okay. Does your signature appear on the. 8 document? 0 A. Yes. 10 Q. Is that your signature? 11 A. Yes. 12 MR. CUOMO: Referring to the bottom of the 13 first page of the document? 14 MR. FALLER: Yes. 15 0. Referring to the bottom portion next to the 16 yellow label of Plaintiff's Exhibit 10. Directing 17 your attention to Page 8 of the tax return. Do you 18 see this page? 19 A. I do. 20 Q. Did you indicate in this tax return that 21 you worked 60 hours a week on the Terramar Project? 22 A. Yes. 23 C. Did you have other officers at that time 24 that worked for the Terramar Project? 25 A. Well, Dana done 23 hours. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324006 EFTA_00I96091 EFTA01306457 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 53 April 9, 2019 1 GHISLAINE MAXWELL 2 Q. Is that accurate? 3 A. I'm sure it is. 4 Q. Who are the other people that you have 5 listed? 6 A. Larry Kevin. Q. Who was he? B A. He was the director. 0 Q. You have him one hour, one hour a week? 10 A. It says average hours per week. One hour a II week. 12 Q. What did he do for the Terramar Project? 13 A. He gave advise as to how to best practices 14 for charity. 15 Q. What about Ariadne Calvo-Platero, what did 16 that person do? 17 A. She again gave advise as to how far 18 Terramar could realize its goals. 19 Q. Are there any other employees for the 20 Terramar Project that are not listed on the tax 21 return? 22 A. The Terramar Project didn't have any 23 employees. 24 Q. These are merely the officers of the 25 company? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324007 EFTA 00196692 EFTA01306458 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 54 April 9, 2019 GHISLAINE MAXWELL A. Yes. Q. How did they get paid? 4 A. They didn't get paid. Q. Were there any salaried employees? A. No. 7 MR. FALLEK: Mark this as 11. 8 (Whereupon, the 2013 Tax Return was 9 received and marked as Plaintiff's Exhibit 11 10 for identification, as of this date, by the 11 reporter.) 12 Q. In 2012 the principal place of business 13 Terramar Project was located at 116 East 65th 14 Street, New York, New York? 15 A. Again. That would be just an address of 16 convenience, but yes. 17 Q. In 2013, was the principal place of 18 business for the Terramar Project also listed at 11, 19 East 65th Street, New York, New York? 20 A. Yes. 21 Q. Directing your attention to, and not a 22 numbered paged, page 5 of the tax returns. 23 Is there a schedule of varies personnel 24 that worked or were officers for Terramar Project. 25 A. These are just all directors and none of DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324008 EFTA_00I98693 EFTA01306459 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 55 April 9, 2019 1 GHISLAINE MAXWELL 2 them were renumerated. Nobody was paid. But, 3 Terramar Project did have work called contract 4 contractors who did do work for it. A contract 5 employee or contract person that worked for the 6 company is not the same as a regular employee. They 7 wouldn't come to work. 9 Q. Who was that? 9 A. I have had a number of -- I had a number of 10 different people. We also have one person who did 11 work for Terramar Project. They were always 12 offsite, because they would never come to work. 13 They would be remote. 14 0. Were there any contracting employees back 15 in 2015 for Terramar Project, Inc.? 16 A. There were, yes. 17 Q. Who were they? 18 A. One. I believe it was Robert Foos. 19 Q. In what position did he hold? 20 A. I think his official title was Director Of 21 Development. 22 Q. Does the additional data sheet indicate 23 that you were also working 60 hours a week for 24 Terramar Project back in 2013? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324009 EFTA_00I 96694 EFTA01306460 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 56 April 9, 2019 GHISLAINE MAXWELL 2 MR. FALLER: Mark this. 3 (Whereupon, the 2014 Tax Return was 4 received and marked as Plaintiff's Exhibit 12 5 for identification, as of this date, by the 6 reporter.) 7 MR. FALLEK: I will show you what was marked as Plaintiff's Exhibit 12 for identification. 10 Q. I'm asking you if you recognize this to be 11 the 2014 Tax Return for Terramar Project? 12 A. Again, I have not seen this document, but 13 actually it seems to be as you described it. 14 Q. At that time the principal place of 15 Terramar Project was at 116 East 65th Street, New 16 York, New York? 17 A. Again, it was just the address that we had 18 of convenience. 19 Q. Did you have another address for the 20 _erramar Project back in 2014? 2: A. No. 22 Q. What about in 2015, did it have any other 23 addresses? 24 A. No. 25 Q. Did it have any other places of business? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324010 EFTA_00I96695 EFTA01306461 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 57 April 9, 2019 GHISLAINE MAXWELL A. No. 3 Q. Directing your attention to the second page 4 of this document. Again, are the officers of the 5 Terramar Project listed on this page? 6 A. Yes. 7 Q. Are you listed working 60 hours a week for 8 the Terramar Project? 9 A. Yes. 10 Q. Was there a 2015 Tax Return filed for the 11 Terramar Project? 12 A. I'm sure there was. 13 Q. Do you know where that? 14 A. T am sorry, I don't. 15 Q. Was it filed with New York State? 16 A. It would have been filed with whatever was 17 compliant and necessary for the paperwork. 18 0. Other than for generalities, do you know 19 where that tax return is? 20 A. No, I don't. 21 Q. Do you know who prepared it? 22 A. I am sorry, I don't recall. 23 Q. Was the accountant that prepared it Mark, 24 Paneth 6 Shron, LLP., 685 Third Avenue, New York, 25 New York 100017, as indicated on Plaintiff's Exhibit DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324011 EFTA_00I96096 EFTA01306462 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 58 April 9, 2019 1 GHISLAINE MAXWELL 2 10? 3 A. It may have been. Were they your accountants? A. They were. 6 Q. Do they always file your personal tax 7 returns and the tax returns for the Terramar 8 Project? 9 A. They did. 10 Q. What about Ellmax, LLC., did they prepare 11 or file those tax returns for you? 12 A. I believe they did. 13 Q. Did you sign all those tax returns 14 yourself? 15 A. I did. 16 Q. On behalf of you personally, Ellmax, and 17 the Terramar Project? 18 A. Yes. 19 Q. How did you first become aware of this 20 accident? 21 A. I believe, as much as I can recall, 22 somebody rang the doorbell. And I had heard 23 somebody had alleged they fell outside on the 24 sidewalk. 25 Q. Was that on September 9, 2015? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324012 EFTA_00I96697 EFTA01306463 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 59 April 9, 2019 1 GHISLAINE MAXWELL 2 A. I guess. I don't remember the date. But, 3 yes. 4 Q. Did you answer the door yourself? 5 A. No. 6 Q. Who answered the door? 7 A. Either Maritsa or Dana. One of them did. 8 Q. What did they tell you? 9 A. They told me that somebody alleged that 10 they fell on the sidewalk. 11 Q. What did you do? Did you leave the house? 12 Did you walk outside and check on the person and see 13 what was going on? 14 A. No, I did not. 15 Q. Did you ever see the individual? 16 A. No. 7 believe by the time I knew about it, 17 I think he had already gone or left. 18 Q. How much time was it that lapsed between 19 the time they told you about it and when you went 20 out? 21 A. I don't remember. I am sorry. 22 Q. Did you do any investigation yourself? 23 A. Did you go in and look at the alleged place 24 where he fell afterwards subsequently. 25 Q. How did you know what the place was that DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324013 EFTA_00I96698 EFTA01306464 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 60 April 9, 2019 GHISLAINE MAXWELL 2 you are saying that he complained of? 3 A. I think Dana mentioned to me where he or 4 she had fallen or claimed to have fallen. 5 Q. Did Dana offer any medical attention or 6 attention to him? 7 A. I don't know. 8 Q. Did she say whether she called an 9 ambulance? 10 A. I don't think she did. I don't know. I 11 think by the time she -- as much as I can recall 12 there was an ambulance that was called. And I think 13 she told me there was an ambulance that was called 14 and that he was going away in an ambulance. 15 Q. Did you see the ambulance arrive? 16 A. No. 17 Q. Did you see him on the sidewalk after she 18 told you about the accident? 19 A. No. 20 Q. After the accident occurred, did you or 21 anybody on your behalf make any changes or repairs 22 to the sidewalk in front of your home? 23 A. No. 24 MR. FALLEK: Can we have this collectively 25 marked. DEIT. Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324014 EFTA_00I 96699 EFTA01306465 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 61 April 9, 2019 1 GHISLAINE MAXWELL 2 (Whereupon, the copies of photographs from 3 Plaintiff's Notice were received and marked as 4 Plaintiff's Exhibits 13A through 13E for identification, as of this date, by the 6 reporter.) 7 Q. Before we get to the photos. When did 116 8 East 65th Street sell the building at 116 East 65th 9 Street? 10 A. It's a matter of record. You can check. I 11 think it was in April of 2016. Is that right? 12 I'm sorry, I don't recall. Something like 13 that. Whatever is the matter of record you will 14 have it. 15 Q. I'm directing your attention to Plaintiff's 16 Exhibit 5 for identification. Your own affidavit. 17 A. Yes. 18 Q. Does the affidavit indicate the date it was 19 sold? 20 A. Yes. 2: Q. When was it sold? 22 A. April 14, 2016. 23 Q. How many was it sold for? 24 A. 15 million and 50,000. Something like 25 that. DEITZ Court Reporting... A Lexitas Company BCC-678-0166 SDNY_GM_00324015 EFTA_00I96700 EFTA01306466 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 62 April 9, 2019 1 GH:SLAINE MAXWELL 2 Q. Before 116 East 65th Street purchased the 3 building, did you have an engineer doing an 4 inspection on the house and the exterior of the house? 6 A. Before I bought it? 7 Q. Yes. 8 A. Sorry, I don't recall. 9 Q. Did you inspect the condition of the 10 sidewalk before you purchased it? 11 A. I don't recall looking at the sidewalk at 12 all. 13 MR. CUOMO: Are you asking just if she 14 inspected the sidewalk in 2000 before it was 15 purchased? 16 MR. FALLEK: Yes. At that time. 17 A. I don't recall ever looking at the 18 sidewalk. 19 MR. FALLEK: I'm going to show you what has 20 been marked as Plaintiff's Exhibits 13A, B, C, 21 D, and E. 22 MR. CUOMO: I'm just curious. I got your 23 note with those photographs. Is there any 24 indication when those photographs were taken? 25 MR. FALLEK: Not in what I have exchanged DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324016 EFTA_00I96701 EFTA01306467 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 63 April 9, 2019 1 GRISLAINE MAXWELL with you, no. Off the record. 3 (A discussion was held off the record.) Q. I just want you to take a look at the 3 pictures. Do you recognize what the building that is shown in Plaintiff's Exhibit 13A? A. This looks like 116 East 65th Street. B Q. Does that show the front of the building? A. A little bit of the front of the building. 10 Q. Does it also show tree roots in the 11 building? 12 A. It does. 13 Q. Do you see the 14 MR. CUOMO: Tree roots in the building? 15 MR. FALLEK: Yes, tree roots in front of 16 the building. 17 A. Yes. In this I do. 18 Q. Take a look at 138. Do you recognize that 19 photo? 20 A. I haven't seen those photos. 21 Q. I understand. 22 A. What are you asking me 23 Q. Do you recognize the upper portion of the 24 photo? 25 A. I do. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324017 EFT,k_00196702 EFTA01306468 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 64 April 9, 2019 GRISLAINE MAXWELL Q. What does that show? 3 A. It shows the front entrance of 116 4 Q. Directing your attention to the next photc 5 13C. Could you tell me what that shows? 6 A. It looks like the tree in front of 7 Diandra's house. 8 Q. Does it also show the tree well or the 9 metal gate around the tree? 10 A. I does. 11 Q. Was that metal grate around the tree was 12 that changed or altered in any way from the time 13 period you lived there? 14 A. I don't remember. I don't know. I don't 15 know. I am sorry. I can't tell from this picture. 16 Q. Could you tell me what is shown in 17 Plaintiff's Exhibit 13D? 18 A. It looks like a sidewalk with tree roots. 19 Q. Do you recognize the metal fence and 20 grating? 21 A. I think that's the metal fence in front of 22 114 and 116 East 65th Street. 23 Q. Did you understand that to be what was the 24 dividing line between the two properties? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324018 EFTA_00196703 EFTA01306469 FILED: NEW YORK. COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 65 April 9, 2019 GHISLATNE MAXWELL 2 Q. Do you recognize what is shown in the last 3 photo marked as Plaintiff's 13E? 4 A. It's a tree well and tree roots. 5 Q. Is that the same tree well? 6 A. I don't know how to answer that. I can't 7 tell. B Q. That's it. I just want to check my notes. 9 A. Could I take a look at this first? 10 Q. Sure. 11 MR. CUOMO: Check away 12 Q. Back in 2015, did you have an office in 13 place outside of 116 East 65th Street? 14 A. I didn't have an office at 116 East 65th 15 Street. 7 have a place where I would sit with my 16 computer. That's the same whether I am in a hotel 17 room. I am mobile. Wherever 7 am is where I work. 18 MR. FALLEK: I will ask the question again. 19 If you could just answer. 20 Q. Did you maintain an office, a physical 21 office, outside 116 East 65th Street, back in 22 September of 2015? 23 A. No. 24 0. Did you pay rent for any office outside of 25 the building, 116 East 65th Street, to maintain an DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324019 EFTA 00196704 EFTA01306470 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 66 April 9, 2019 1 GHISLAINE MAXWELL 2 office? 3 A. No. 4 MR. FALLEN: I have no further questions. 5 MR. CUOMO: I just have a few. 6 EXAMINATION BY 7 MR. CUOMO: 8 Q. Afternoon Ms. Maxwell. How are you? 9 A. Good, thanks. 10 Q. Before it was mentioned that the house at 11 116 East 65th Street was designated as a two-family 12 home. 13 A. I think in the paperwork it has two-family 14 home. 15 Q. When it was purchased in 2000, do you 16 recall if you purchased it using 116 East 65th 17 Street, LLC.? 18 A. I believe I did. 19 Q. Were you the sole member of 116 East 65th 20 Street, 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. 25 Q. At the time that the home was purchased, DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324020 EFTA_00196705 EFTA01306471 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 67 April 9, 2019 GNISLAINE MAXWELL 2 was it being used as a two-family home? 3 A. I don't recall. 4 Q. To your mind, was the home you had 5 purchased was it set up as a two-family home? 6 A. No. 7 Q. Was it set up as a single-family home? A. Yes. 9 Q. From that point in 2000 until you sold it, 10 on April 14, 2016, did you use it as a one-family 11 home? 12 A. Yes. 13 Q. You never rented out any portion of that 14 home to any other family or any other resident? 15 A. No. 16 Q. Now, there was some discussion with an 17 office in the house, as listed on the diagram, that 18 was used to help sell the home. Do you recall that 19 a few moments ago? 20 A. Yes. 21 Q. Was that office designated for use solely 22 by either the Terramar Project or Ellmax? 23 A. No. 24 Q. Did that office exist in the home when you 25 bought it? DEITZ Court Reporting... A Lexitas Company 800-678-0166 S0NY_GM_00324021 EFTA_00196706 EFTA01306472 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 68 April 9, 2019 GHISLAINE MAXWELL 2 A. No. 3 Q. Did the room exist in the home? 4 A. Yes. 5 Q. At some point you put a desk and computer 6 in there? 7 A. Yes. 8 Q. Prior to, say, 2010, did the office exist? 9 A. I think so. 10 Q. Prior to 2010 what did you use the office 11 for? 12 A. It was the place where the dogs come to get 13 fed, and where you could stage food and drinks for 14 the garden. 15 Q. were there any place in the home, at 116 16 East 65th Street, that was reserved for use by 17 employees either by Ellmax or the Terramar 18 A. No. 19 Q. Now, you mentioned that the Ellmax was 20 dormant after 2013. What do you mean by dormant? 21 A. I wasn't performing any work. 22 Q. It was still an actual LLC? 23 A. Yes. 24 Q. Some time in 2017 you kind of woke it up 25 just to dissolve it? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324022 EFTA_00196707 EFTA01306473 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 69 April 9, 2019 1 GHISLAINE MAXWELL 2 A. Yes. 3 Q. Between 2013 and 2017, is it correct, that 4 you did no business for the Ellmax, LLC.? 5 A. No. 6 Q. Between 2010 and 2013 when you did business 7 with Ellmax, did any of your clients or potential clients ever come to the home to do business? 9 A. No. 10 Q. Did you ever entertain anybody from the 11 general public with respect to Ellmax between 2010 12 and 2013 in the home? 13 A. No. 14 Q. Did Ellmax sell any products of any kind? 15 A. No. 16 Q. Did you ever offer for sale through Climax 17 any products out of your home? 18 A. No. 19 was there any retail space in your home? 20 A. No. 21 Q. Was there any wholesale space in your home? 22 A. No. 23 Q. Between 2000 and 2016, when you sold the 24 property, was it essentially a primary residence? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324023 EFTA_00196708 EFTA01306474 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 70 April 9, 2019 1 GHISLAINE 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 116 East 65th Street? 6 A. Yes. Q. That was all the time between 2000 thru 2016? 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. 14 Q. Have you received any remuneration of any 15 kind from the Terramar Project for your service for 16 that not-for-profit entity? 17 A. No. 18 Q. Is there any place in the home, at 116 East 19 65th Street, that is set aside for use solely by the 20 Terramar Project? 21 A. No. 22 Q. Did you ever take any tax deductions on 23 your personal income taxes relative to a home office 24 that was for use by Ellmax or the Terramar Project 25 or any other commercial entity between 2010 and DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324024 EFTA_00I96709 EFTA01306475 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 71 April 9, 2019 1 GHISLA1NE MAXWELL 2 2015? 3 A. No. 4 Q. That office that we Calked about off the 5 garden, could you use that for any personal 6 purpose? 7 A. Yes. B Q. If you wanted to sit down and type out 9 letter to somebody, could you use that office if it 10 was a personal matter? 11 A. Yes. 12 Q. Were you restricted in anyway for using 13 that small portion of your home for any personal 14 issue? 15 A. No. It was where the dogs got fed. It was 16 there all the time. 17 Q. I'm showing you Plaintiff's Exhibit 6. Do 18 you recognize that photograph? 19 A. Yes. 20 Q. Does that photograph show portions of both 21 116 and 114 East 65th Street here in New York? 22 A. Yes. 23 Q. Does it show portions of the sidewalk that 24 are in front of both 114 and 116 East 65th Street? 25 A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324025 EFTA_001967I0 EFTA01306476 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 72 April 9, 2019 GHISLATNE MAXWELL 2 Q. Does it show a tree well and a metal guard 3 around that tree well? 4 A. Yes. 5 Q. Is that tree well and that metal guard 6 around that tree well predominantly in front of 114 7 East 65th Street? 8 A. Yes. 9 0. At any time, from the year 2000 until you 10 sold the property in April of 2016, did you contract 11 for hire anyone to do any repairs to the sidewalk in 12 front of 116 East 65th Street? 13 A. No. 14 Q. Mr. Fallek showed you a series of 15 photographs marked as 13A through 13E depicting a 16 sidewalk and some type of construction or repair. 17 You have see those? 18 A. I did. 19 Q. At any time during your ownership or during 20 the LLC's ownership of 116 East 65th Street, did you 21 have any work done that would have resulted in 22 photographs like this being taken? 23 A. No. 24 Q. Did the Terramar Project ever host any 25 events or have any events at your home between when DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324026 EFTA_0Ol967Il EFTA01306477 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 73 April 9, 2019 1 GHTSLAINE MAXWELL 2 you started it up say in 2011 or whenever you 3 started it up through April 14, 2017, when you sold 4 the home? 5 A. No. 6 Q. Did you ever have any event where the 7 general public was invited to the home for any a purpose for the Terramar Project such as a fund 9 raiser or anything like that? 10 A. No. 11 Q. With respect to Ellmax, I just want to make 12 an understanding. Is it fair to say the business of 13 Palmas was you either attempting to place board 14 members for companies or search for board members of 15 companies or both? 16 A. Yes. 17 Q. Would you also, from time to time, attempt 18 to source speakers for company functions? 19 A. Yes. 20 Q. You might also help them with the event 21 planning and venue selection for a company? 22 A. I didn't do event planning. 23 Q. Venue selection perhaps? 24 A. Yes. 25 Q. When you worked for a particular company, DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324027 EFTA 0019671? EFTA01306478 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 74 April 9, 2019 1 GHISLAINE MAXWELL 2 did you work with them at their premises? 3 A. Yes 4 Q. Did you ever had them come to your S business, to 116 East 65th Street, to do that work? 6 A. No. Q. During the period of time that Ellmax functioned, did it generate revenue? 9 A. A small amount. le Q. Did you ever collect a salary for Ellmax? 11 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 17 2013? 18 A. It just was used to defer 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 companies I would have 23 worked for were from Los Angeles. I went to LA and 24 also to London multiple times. 25 Q. What was the reason you stopped working DEIT2 Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324028 EFTA_00196713 EFTA01306479 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 75 April 9, 2019 I GHISLAINE MAXWELL 2 through or working as part of Ellmax in 2C13? 3 A. It wasn't going to succeed and it was just 4 useless. And I just stopped it. 5 Q. Ellmax between 2013 and the time you sold 6 the home in 2016 it had no revenue? A. No. Q. It did not operate? 9 A. No. :0 Q. You listed the home at 116 East 65th Street :1 as an address for both Terramar Project and Ellmax, 12 correct? 13 A. Just as an address of convenience. 14 Q. Was that to receive mail? 1S A. Yes. 16 Q. To have an address for the tax return? 17 A. Yes, or whatever. 18 Q. Other than those purposes, did 116 East 19 65th Street serve any purpose for the operations of 20 either Ellmax or the Terramar Project at any time 21 between 2010 and 2016 when you sold the home? 22 A. It was just my home. It was just my home. 23 That's where I stayed. 24 N.R. CUOMO: No further questions. 25 MR. FALLEK: I have one more thing. If you DEM. Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324029 EFTA_001967I4 EFTA01306480 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 76 April 9, 2019 1 GHISLAINE MAXWELL 2 could mark this. 3 (Whereupon, the Real Project Transfer was 4 received and marked as Plaintiff's Exhibit 14 5 for identification, as of this date, by the 6 reporter.) 7 EXAMINATION BY 8 MR. FALLEK: 9 Q. I will show you a document, which was 10 marked as Plaintiff's Exhibit 14 for identification. 11 A. What is it? 12 Q. Is this the Real Property Transfer for the 13 sale of 116 East 65th Street? 14 A. Real property transfer is -- I don't know. 15 MR. CUOMO: If you don't know, you don't 16 know. 17 A. I'm sorry, I don't know. I have never seen 18 this docUment. 19 Q. Did you attend the closing when you sold 20 the building at 116 East 65th Street? 21 A. No. 22 Q. Did you authorize somebody to attend the 23 closing for you? 24 A. Yes. 25 Q. Who was that? CEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324030 EFTA_001967I5 EFTA01306481 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 77 April 9, 2019 1 GHISLAINE MAXWELL 2 A. The lawyer that is on that. I don't 3 remember his name. Monte Albers De Leon. 4 Q. Who is he? Is he your lawyer? 5 A. He was a lawyer that I used. 6 Q. Did you sign a Power Of Attorney permitting 7 him to execute documents on your behalf? 8 A. I don't remember. I must have. 9 Q. Was the property sold to a Mr. Greenberg? 10 A. I'm sorry, I don't remember the name of the 11 person who bought it. I'm sorry. 12 Q. Have you ever met Monte Albers De Leon? 13 A. I have. 14 Q. In what capacity? 15 A. He was a lawyer. 16 Q. Was he your lawyer for this matter? 17 (Continued on the next page for the jurat.) 18 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324031 EFTA_001967I6 EFTA01306482 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 78 April 9, 2019 1 GHISLAINE MAXWELL 2 A. He was my lawyer for this matter. 4 MR. FALLEK: No further questions. Thank 5 you. 6 (Whereupon, the proceedings were concluded at 11:47 a.m.) 8 9 10 11 GHISLAINE MAXWELL 12 13 Subscribed and sworn to 14 before me this ____ day 15 of , 2019. 16 17 Notary Public 18 19 20 2: 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324032 EFI;k_001967I7 EFTA01306483 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 79 April 9, 2019 1 I ND E x 2 EXAMINATION BY PAGE 3 Mr. Fallek 6 4 76 5 Mr. Cuomo 66 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324033 EFTA_00196718 EFTA01306484 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 80 April 9, 2019 1 REQUESTS 2 PAGE 3 NONE 4 5 RULINGS 6 Page Line 7 NONE 8 9 10 11 12 13 ( 14 15 16 17 le 19 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324034 EFTA_001967I9 EFTA01306485 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 81 April 9, 2019 1 EXHIBITS 2 EXHIBIT DESCRIPTION PAGE 3 1 Document dated 9-18-14 13 4 2 Document dated 2-23-15 13 5 3 Document dated 3-22-16 13 6 4 Document dated 4/5/19 22 7 5 Affidavit 27 8 6 Copy of a photo 34 7 Copy of a photo 42 1C 8 A draft 46 11 12 EXHIBITS 13 EXHIBIT DESCRIPTION PAGE 14 9 A draft 46 15 10 2012 tax document 51 16 11 2013 tax document 54 17 12 2014 tax document 56 18 13A-13E Copies of photographs 60 19 14 Real Property Transfer 20 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324035 EFTA 00196720 EFTA01306486 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 Page 82 April 9, 2019 1 2 CERTI FICATION 3 4 I, Theresa Acosta, a Shorthand Reporter 5 and Notary Public of the State of New York, do 6 hereby certify; 7 8 That, GHISLAINE MAXWELL, the witness whose 9 examination is hereinbefore set forth, was duly 10 sworn, and that such examination is a true record of 11 the testimony given by such witness. 12 13 I further certify that I am not related to 14 any of the parties to this action by blood or 15 marriage; and that I am in no way interested in the 16 outcome of this matter. 17 lE 19 20 THERESA ACOSTA 21 22 23 24 25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324036 EFTA 00196721 EFTA01306487 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 g iCrIVID, IMF: 03/05/2020 Page 83 20:11,17 30:23 62:13 63:22 9:4,8,12 17:8 a.m (2) 31:9,12,22 answer (9) aspect (1) 17:25 18:12 1:13 78:7 35:22 54:15 7:14,21 20:14 28:9 31:19 32:16 abilities (1) 56:17,19 20:21 31:4 assets (2) 35:2 41:2,5 14:23 75:11,13,16 45:16 59:4 21:2,3 41:20 44:12 able (3) addresses (I) 65:6,19 assistance (1) 44:17 45:22 14:13,25 56:23 answered (2) 11:24 47:25 48:21 16:21 advise (7) 41:4 59:6 assistant (8) 49:5 50:2 above-atilt - 12:13 14:14 anybody (12) 16:3,4,11,21 55:14,24 1:17 28:8 32:12 35:14 36:25 23:2,19 56:20 65:12 AC (I) 32:13 53:13 37:13 38:3,5 29:14 30:7 65:21 49:16 53:17 38:7 39:8,19 assume (2) background... access (I) advised (2) 39:24 41:17 7:21 17:23 10:23 48:19 28:7 66:22 60:21 69:10 assuming (1) bag (3) accident (4) advising (I) anymore (1) 17:19 43:4,7,9 6:18 58:20 14:18 16:7 attempt (1) bar (2) 60:18.20 affidavit (7) anytime (1) 73:17 3:13 5:10 accountant (6) 27:6,11,18,25 36:17 attempting (1) Barr (2) 17:22,25 26:5 61:16,18 anyway (I) 73:13 1:5 6:15 32:11 57:23 81:7 71:12 attend (2) based (3) 66:23 Afternoon (1) apologize (1) 76:19,22 32:11.13 accountants.- 66:8 39:6 attention (10) 50:23 58:4 against- (I) appear (1) 13:16 17:13 basement (3) accurate (1) 1:7 52:7 19:23 52:17 33:13,14 53:2 ago (2) appeared (I) 54:21 57:3 49:12 accurately (3) 26:12 67:19 35:2 60:5,6 61:15 basic (1) 34:25 47:6 agreeable (1) appears (2) 64:4 7:2 49:3 7:17 43:13 52:6 Attorney (3) bathroom (I) Acosta (2) AGREED (6) April (6) 2:4,9 77:6 51:15 82:4,20 3:3,17 4:6,12 1:13 61:11,22 August (I) bathrooms (1) action (6) 4:18,24 67:10 72:10 45:24 33:22 1:17 3:15 5:12 AIGPRIV (I) 73:3 authorize (1) Battery (1) 6:15 11:25 2:12 area (3) 76:22 2:4 82:14 Albers (2) 14:25 38:4 Avenue (4) Beach (1) actual (1) 77:3,12 47:11 1:11 25:531:9 31:10 68:22 alleged (3) Astatine (1) 57:24 bedroom (I) add (1) 58:23 59:9,23 53:15 average (1) 70:4 30:14 altered (1) arrive (1) 53:10 bedrooms (I) added (1) 64:12 60:15 aware (1) 33:20 30:12 ambulance (5) articles (I) 58:19 begun (1) addition (2) 60:9,12,13,14 31:25 3:22 60:15 aside (1) B behalf (7) 3:11 5:8 additional (1) amount (1) 70:19 B (3) 35:15 36:25 55:22 74:9 asked (2) 62:20 81:1,12 37:13 44:9 address (21) Angeles (1) 21:11 30:8 BA (2) 58:16 60:21 74:23 asking (8) 11:3,7 77:7 6:10 7:25 8:13 annual (5) 6:17 15:23 bachelor's (1) believe (19) 15:18 17:4 18:16 19:15 13:20 17:20 30:10 32:16 11:5 18:8 19:18 19:17,19 20:5 26:6 37:23 56:10 back (28) 20:17 21:6,9 6:18 8:7,22,25 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324037 EFTA_00196722 EFTA01306488 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 April 9, 2019 Page 84 21:16 22:12 building (29) cage (1) 1:8 29:9 39:24 21:5 24:19 22:15 24:20 26:15,19 33:7 35:10 claimed (1) 24:21 28:2 24:25 25:3 33:11,17 call (I) 60:4 30:16 53:25 29:24 38:16 34:2,7,21,25 30:3 clarify (I) 55:6 73:18. 44:2 55:18 35:14 43:25 called (7) 30:10 73:21,25 58:12,21 44:6,1749:4 6:225:17 clean (2) complain (1) 59:16 66:18 49:8,13,15 47:10 55:3 41:9,18 39:19 belonging (1) 49:22 50:9 60:8,12,13 cleanup (1) complained... 35:19 61:8 62:3 Calvo-Plate... 41:10 60:2 best (1) 63:5,8,9,11 53:15 clear (1) compliant (1) 53:13 63:14,16 capacity (1) 40:24 57:17 between(am-. 65:25 76:20 77:14 client (2) computer (4) 3:4,18 4:7,13 buildings (I) card (1) 26:24 50:20 47:16,17 4:19,25 38:12 10:19 clients (2) 65:16 68:5 Beware (1) Burns (3) care (1) 69:7.8 computers (1) 44:8 16:2 22:23 41:14 closing (2) 47:15 big (3) 29:20 certain (1) 76:19,23 concluded (1) 38:20 47:11 business (32) 18:14 coffee (2) 78:6 49:21 9:17,19 12:18 Certificate (2) 48:17,18 condition (4) birth (1) 14:11,23 43:20.22 collect (2) 39:16,20,25 10:5 15:3,11 17:3 certification... 70:11 74:10 62:9 bit (I) 19:12 20:9 4:14 11:21 collected (I) conduct (3) 63:9 20:12,16,24 certify (2) 70:11 5:4 50:15,18 blood (1) 25:22,24,25 82:6,13 collectively (1) conferences... 82:14 28:10 32:6 chance (1) 60:24 9:21 12:16.16 blow-up(1) 43:1549:23 27:23 combined (1) 12:17 14:15 48:24 49:25 50:3 changed (4) 11:9 14:16 28:10 board (8) 50:15,18 8:24 19:17 come (9) 28:11 12:14,14 54:12,18 31:22 64:12 22:8 26:14 confused (1) 14:14,17,21 56:25 69:4,6 changes (3) 40:17 50:14 21:25 16:25 73:13 69:8 73:12 35:15 37:12 55:7,12 connection (I) 73:14 74:5 60:21 68:12 69:8 25:8 boards (I) businesses (4) character (1) 74:4 construction... 28:9 12:14 14:19 14:22 commercial... 72:16 books (1) 28:8,8 charge (I) 70:25 consultation... 26:2 buzz (2) 4:22 common (1) 28:4,5 born (I) 45:9.10 charity (1) 32:8 Cont'd (2) 10:3 buzzer (2) 53:14 communicat.. 4:2 5:2 bottom (2) 44:25 45:6 cheek (4) 23:11 contact (1) 52:12,15 buzzers (1) 59:12 61:10 companies (8) 15:7 bought (3) 45:7 65:8.11 9:2 14:14,15 Continued (1) 62:6 67:25 — -- — children (1) 14:18 15:2 77:17 77:11 --- C---- 40:8 73:14,15 continuousl... branches (1) C (4) chose (1) 74:22 21:18 36:23 2:2 62:20 82:2 18:9 company (20) contract (4) break (2) 82:2 citizen (5) 12:13,22 14:5 55:3,4,5 72:10 41:12 51:17 CPIS (4) 10:7,9,13,19 14:22 15:16 contracting... broker (2) 3:7 4:3,10 5:3 10:21 16:16 17:16 55:14 32:18,21 cabinet (2) City (3) 18:4,10 20:5 contractor (1) 50:6,7 DEITZ Court Reporting... A Lexitas Company 800-628-0166 SONY_GP0_00324038 EFTA_00196723 EFTA01306489 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pt. INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 April 9, 2019 Page 85 42:3 creation (I) 78:14 44:3 67:16 contractors ... 24:16 days (2) desk (6) dissolve (I) 55:4 Cuomo (22) 40:17 41:5 47:20,23,25 68:25 controlled (1) 2:8,11 24:6 Dc (2) 50:10,14 dissolved (I) 4:4 26:23 30:10 77:3,12 68:5 19:21 convenience... 31:20 37:15 dealing (1) desktop (3) dividing (1) 15:18 19:16 37:19 38:9 26:5 47:19,22 64:24 20:11,18 40:24 41:12 December (1) 48:11 document (32) 54:16 56:18 43:7 52:12 10:6 Detroit (1) 13:4,8,12,17 75:13 62:13,22 decide (1) 17:7 13:19,22 cop (I) 63:14 65:1 50:11 Developmen... 15:9 19:25 50:14 66:5,7 75:24 deductions (2) 55:21 22:18,22 copies (2) 76:15 79:5 28:22 70:22 diagram (6) 23:24,25 61:2 81:18 curious (1) deed (1) 46:4,8.18,22 24:2,4 34:10 copy (6) 62:22 8:20 47:4 67:17 34:24 51:12 4:20 34:12 current (I) deemed (I) Diandra (5) 51:18 52:2,8 42:17 48:4 17:4 3:25 36:4,5 37:9 52:13 56:12 81:8,9 Defendant (2) 39:8,12 57:4 76:9,18 cordoned (1) D 1:15 2:9 Diandra's (6) 81:3,4,5,6,15 49:10 D (2) Defendants ... 36:20 37:6 81:16,17 Corporation-. 62:21 79:1 1:9 38:17,18 documents (4) 51:8 Dana (13) defer (I) 39:11 64:7 13:2 15:15 correct (4) 16:2 22:23 74:18 different (8) 27:2 77:7 10:2 40:21 29:16,20 degree (2) 9:16 16:16,17 dog (7) 69:3 75:12 44:13 45:20 11:9,10 18:17 20:15 44:5,8,11,13 cost (1) 45:21 48:11 degrees (2) 22:2 23:18 44:13,15,19 74:18 48:11 52:25 11:11,13 55:10 dogs (2) costs (1) 59:7 60:3,5 demonstrate... dining (1) 68:12 71:15 74:20 Darren (1) 35:17 50:12 doing (3) counsel (9) 25:4 Department ... directed (2) 7:5 9:21 62:3 1:20 3:4,18,24 data (1) 24:2 16:25 38:5 door (12) 4:7,13,19,21 55:22 depicted (4) directing (9) 42:7 43:8,11 4:25 date (17) 37:11,21 13:16 17:13 44:20,20 count (1) 10:5 13:6,10 46:21 47:4 19:23 37:18 45:4,4,6,16 33:15 13:14 22:20 depicting (I) 52:16 54:21 48:16 59:4,6 countries (1) 27:13 34:14 72:15 57:3 61:15 doorbell (2) 10:15 42:19 46:6 Depositions ... 64:4 45:15 58:22 country (3) 46:10 51:20 5:5 director (2) doors (1) 2:10 10:13 54:10 56:5 describe (I) 53:8 55:20 44:22 11:22 59:2 61:5,18 33:7 directors (5) dormant (4) COUNTY (1) 76:5 described (I) 12:15 14:14 30:19 31:6 1:3 dated (8) 56:13 14:17,21 68:20,20 course (1) 13:4,8,12 DESCRIPT... 54:25 Double (1) 7:6 22:18 81:3,4 81:2,13 disbursed (1) 11:10 court (5) 81:5,6 designate (1) 74:12 Douglas (2) 1:2 7:3,14,25 dates (3) 41:17 discuss (3) 32:24 36:5 27:4 19:10 31:14 designated (2) 7:2 35:24 37:9 draft (2) create (3) 31:19 66:1 1 67:21 discussion (3) 81:10,14 25:9,10,13 day (3) designation ... 41:13 63:3 drink (1) 40:19 44:23 DEITZ Court Reporting... A Lexitas Company 8C0-678-0166 SDNY_GkL00324039 EFTA_00196724 EFTA01306490 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RELIVED NYSCEF: 03/05/2020 Page 86 48:20 76:20 54:5 55:14 79:2 82:9,10 Extensively ... drinks (1) education (1) 68:17 examination... 9:14 68:13 10:23 EMT (2) 3:13,22 4:15 exterior (2) duly (2) educational... 11:18,21 4:20 42:4 62:4 6:3 82:9 10:22 engineer (1) examination... duties (I) either (7) 62:3 3:10,19,24 4:8 F 41:7 44:21 59:7 England (3) examined (2) F (I) 66:22 67:22 6:11 10:16,18 3:20 6:4 82:2 E 68:17 73:13 enter (I) exchanged (I) fail (1) E (9) 75:20 42:6 62:25 45:15 2:2,2 6:2,2 elevator (1) entertain (I) Excuse (1) failure (3) 62:21 79:1 34:4 69:10 40:5 3:11,23 5:8 81:1,12 82:2 Elliman (I) entire (1) execute (I) fair (1) E-L-L-M-A-... 32:24 7:13 77:7 73:12 12:9 Ellmax (54) entities (I) Exhibit (43) fairly (3) earlier (I) 12:8,10,19 9:2 13:3,5,9,13,18 34:25 47:6 28:7 13:21 14:3 entity (2) 17:14 19:24 49:3 easier (1) 14:12 15:4 70:16,25 22:17,19 Fallek (55) 15:14 15:16 16:14 entrance (13) 23:22 27:10 2:3,6 6:7,13 East (72) 16:20,24 34:6 42:10,12 27:12,16 6:14,25 7:7,9 1:8,16 2:9 17:16,21 42:13 43:14 31:18 34:11 7:13,19 6:22 8:11 9:6 18:10 19:19 43:15,15,16 34:13,17 12:25 13:16 15:4,11 17:8 20:5,9,15 43:17 44:17 37:21 42:18 15:19,22 19:13 20:9 21:2,7,10,12 44:21 45:2 42:22 45:5 17:13 19:23 21:22 22:14 28:2,19 64:3 46:5,9,13,15 20:13,19 24:3,8,12,18 29:14 30:5,6 entrances (2) 48:23,25 21:25 22:16 25:23 26:14 30:18,19,24 34:7 42:14 51:13,19,24 23:21 27:9 26:15,20 50:4,19 Epstein (2) 52:16 54:9 27:15 30:12 32:2,7,19,22 58:10,16 25:17,20 56:4,8 57:25 30:21 31:17 33:2,3,8 34:7 67:22 68:17 equipment (3) 61:16 63:6 34:10 37:17 34:20,22 68:19 69:4,7 48:8,10,13 64:17 71:17 37:25 38:13 35:13,19 69:11,14,16 Esq (3) 76:4,10 81:2 41:2 42:16 36:18 37:14 70:24 73:11 2:6.11 25:4 81:13 42:21 46:3 37:22,24 73:13 74:7 essentially (1) Exhibits (2) 46:12 48:22 39:13 40:3 74:10,13,15 69:24 61:4 62:20 51:12,16,23 43:11 46:17 74:21 75:2,5 estate (1) exist (3) 52:14 54:7 47:7 49:4 75:11,20 18:19 67:24 68:3,8 56:2,7 60:24 50:15 54:13 Ellmax's (1) evasive (I) existed (1) 62:16,19,25 54:19 56:15 30:13 15:25 49:5 63:15 65:18 61:8,8 62:2 email (I) event (3) existence (I) 66:4 72:14 63:7 64:22 23:12 73:6,20,22 12:11 75:25 76:8 65:13,14,21 emergency (1) events (2) expected (I) 78:4 79:3 65:25 66:11 11:17 72:25,25 17:24 fallen (2) 66:16,19 employed (1) exactly (4) expense (I) 60:4,4 68:16 70:5 12:3 16:19 25:11 31:2 family (I) 70:18 71:21 employee (3) 32:17 36:11 expensive (1) 67:14 71:24 72:7 16:19 55:5,6 examination... 31:3 far (2) 72:12,20 employees (6) 1:15 5:7,10 explained (1) 19:22 53:17 74:5 75:10 21:7 53:19,23 6:6 66:6 76:7 28:7 fax (1) 75:18 76:13 48:6 DEITZ Court Reporting. .. A Lexitas Company 800-678-0166 SONY_GM_00324040 EFTA_00196725 EFTA01306491 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pt INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 gffivt NYSCEF: 03/05/2020 Page 87 fed (2) 18:7,9,12,14 36:14 37:22 generate (1) 82:11 68:13 71:15 18:16,18,19 37:23 38:10 74:8 go (12) Federal (I) 18:22,23,24 38:12 39:20 generated (1) 9:15 11:4 29:6 19:3,5 20:4 39:25 41:16 74:16 32:16 42:9 fee (1) 31:10 41:19 42:7 gentleman (1) 42:1244:20 31:7 focus (1) 42:11,13 25:19 44:21,22 feet (3) 15:22 44:20 45:4 gentlemen (I) 45:15 50:20 47:13,13,14 follows (I) 51:10 60:22 25:17 50:20 59:23 fell (3) 6:5 63:8,9.15 Ghislaine (77) goals (1) 58:23 59:10 food (1) 64:3,6,21 1:16 6:1,9 7:1 53:18 59:24 68:13 71:24 72:6 8:1 9:1 10:1 going (12) fence (2) Foos (1) 72:12 11:1 12:1 6:20 12:25 64:19.21 55:18 full-time (2) 13:1 14:1 23:21 27:20 Fifth (1) foot (1) 23:9.10 15:1 16:1 28:13 31:2 1:11 33:24 functioned (1) 17:1 18:1 35:20 59:13 file (13) footage (1) 74:8 19:1 20:1 60:14 62:19 2:12 28:23,25 33:16 functions (1) 21:1 22:1 74:21 75:3 29:3,4,6,9 form (7) 73:18 23:1 24:1 good (3) 30:23 31:4,7 3:9 5:6 8:18 fund (1) 25:1 26:1 6:13 14:22 50:6 58:6,11 14:3 22:13 73:8 27:1 28:1 66:9 filed (8) 24:8 50:24 funds (1) 29:1 30:1 grate (1) 15:13 17:20 formed (6) 16:17 31:1 32:1 64:11 27:4 31:6 14:7,9 15:10 funny (1) 33:1 34:1 grating (1) 51:9 57:10 19:20 24:10 28:20 35:1 36:1 64:20 57:15,16 32:14 furnished (I) 37:1 38:1 green (1) filing (3) forming (1) 4:21 39:1 40:1 10:19 4:14 50:7,14 32:7 further (9) 41:1 42:1 Greenberg (1) finish (1) forth (2) 3:174:6,12,18 43:144:1 77:9 7:13 9:12 82:9 4:24 66:4 45:1 46:1 guard (2) lint (13) fortunately (... 75:24 78:4 47:1 48:1 72:2,5 6:3 11:18 14:24 82:13 49:1 50:1 guess (2) 13:25 21:17 Four (2) — 51:1 52:1 14:10 59:2 21:23 22:3 33:21,23 - —6 - 53:1 54:1 37:25 45:18 France (3) G —(I) 55:1 56:1 tj _- 49:17 51:14 10:4,16,17 6:2 57:1 58:1 H (3) 52:13 58:19 French (3) garden (5) 59: 1 60:1 6:2 81:1,12 65:9 11:3.8,10 48:19,19,21 61:1 62:1 handle (I) five (3) frequently (I) 68:14 71:5 63: 1 64:i 43:8 27:10 33:12 50:10 gardener (1) 65:166:1 hanging (I) 41:5 Friday (I) 42:4 67:1 68:1 43:7 flight (2) 40:20 Gardner (2) 69:1 70:1 happened (I) 17:2 30:8 fridge (1) 1:5 6:16 71:1 72:1 74:15 floor (3) 48:18 gate (I) 73:1 74:1 head (2) 2:4 49:17 50:8 friend (1) 64:9 75:1 76:1 7:5 15:7 noon (I) 25:15 general (2) 77:1 78:1,11 hear (2) 33:10 friends (1) 69:1 1 73:7 82:8 37:19 45:15 Florida (18) 14:24 generalities ... give(2) heard (1) 12:21 13:20 front (27) 57:18 7:14,21 58:22 14:9 17:15 15:9 35:4 generally (2) given (I) held (3) 47:2 48:12 1:1741:13 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324041 EFTA_00196726 EFTA01306492 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 NYSCEF: 1 03/05/2020 Page 88 63:3 homes (3) 54:10 56:5,9 73:7 30:25 31:25 helicopter (2) 8:7,10 9:2 61:5.16 76:5 involve (1) 32:4,6 38:17 11:18,20 honestly (I) 76:10 6:20 39:6,7.12 help (6) 31:16 important (1) Island (1) 41:23 43:4 14:14 16:23 honors (1) 7:19 31:9 47:21 57:13 40:10 41:10 11:10 inches (2) issue (1) 57:18,21 67:18 73:20 Hoover (I) 47:13.14 71:14 59:25 60:7 helped (2) 41:10 includes (I) --- 60:10 64:14 25:9,13 hoping (1) 33:13 J 64:1565:6 hereinbefor... 28:14 including (2) January (2) 76:14,15,16 82:9 host (1) 3:8 5:5 9:8,23 76:17 hereto (6) 72:24 income (3) Jeff (1) known (1) 3:5,19 4:8,14 hotel (I) 28:23 29:4 25:20 15:16 4:20 5:3 65:16 70:23 Jersey (2) highest (1) hour (3) INDEX (1) 17:12 29:23 L 10:23 53:9,9,10 1:10 job (5) L (6) hire (3) boors (5) ji nn (4) 12:7,8 21:9 3:2 4:2 5:2 6:2 25:10 42:3 52:21,25 15:10 52:20 23:4,9 6:2,2 72:11 53:10 55:23 55:22 61:18 JOSEPH (1) LA (1) hired (2) 57:7 indicated (3) 2:3 74:23 28:17 29:13 house (22) 28:21 29:12 Int (1) label (1) history (3) 24:16 39:9,10 57:25 77:17 52:16 11:3,8,10 39:11 40:11 indicating (1) labeled (1) K 47:11 hold (2) 41:9 42:9 43:5 37:15 55:19 43:18,23 indication (1) keep (3) lapsed (1) holder (1) 45:21,25 62:24 31:2 41:8 50:4 59:18 10:20 46:4,8 47:5,7 individual (1) kept (6) laptop (4) holding (1) 59:11 62:4,5 59:15 45:13 47:15 47:19,21,24 28:2 64:7 66:10 individually... 48:8,13 48:11 home (48) 67:17 70:4 8:17 49:12 50:8 larger (1) 8:6,15,17 housekeeper... indyke (1) Kevin (1) 48:25 18:23 23:6 40:13,14 41:8 25:4 53:6 Lamy (3) 28:22 29:24 inspect (I) 'dud (5) 2:6 6:14 53:6 29:25 30:4 I - 62:9 8:22 47:17 late (1) 31:11 38:11 Idea (I) inspected (1) 68:24 69:14 10:11 40:1841:15 26:12 62:14 70:15 laundry (2) 41:16,20 ideas (I) inspection (I) Kinnerton (I) 41:949:14 46:19 47:9 15:8 62:4 6:I 1 LAW (1) 60:22 66:12 ideotificatio... intention (1) kitchen (1) 2:3 66:14,23,25 13:6,10,14,18 28:3 -1 1 11 lawyer (11) 67:2,4,5,7,11 17:14 19:24 intercom (1) knew (I) 25:7,12 27:5 67:14,18,24 20:3 22:17 44:25 59:16 32:14 66:22 68:3,15 69:8 22:20 23:23 interested (1) hem (40) 77:2,4,5,15 69:12,17,19 27:13,17 82:15 8:23 14:20 77:16 78:3 69:21 70:18 31:19 34:14 interior (1) 16:24 17:5.6 lawyers (1) 70:23 71:13 34:17 42:19 45:9 18:11 19:7.8 15:17 72:25 73:4,7 42:23 45:5 investigation. 22:25 23:7 layout (2) 75:6,10,21 46:6,10,15 59:22 23:15,17 47:749:4 75:22,22 48:24 49:2 invited (1) 24:14,15 lead (1) 51:20,25 26:17 29:25 43:17 DEITZ Court Reporting. .. A Lexitas Company 800-678-0166 SONY_GM_00324042 EFTA_00196727 EFTA01306493 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pt INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 l NYSCEF: 03/05/2020 Page 89 leave (1) 50:14 63:9 9:13,15 mark (6) 34:1 35:1 59:11 live (10) 74:24 27:9 51:13 36:1 37:1 leaves (1) 17:8,11 21:18 long (3) 54:7 56:2 38:1 39:1 36:13 21:20 23:4 8:2 16:4 26:12 57:23 76:2 40:1 41:1 left (1) 23:14 36:7 longer (1) marked (36) 42:1 43:1 59:17 39:840:15 12:11 13:2,5,9,13,17 44:1 45:1 legal (2) 40:15 look (8) 22:16,19 46:1 47:1 32:12,13 lived (19) 13:24 23:23 23:22 27:12 48:1 49:1 !Ma (I) 8:2 9:10 18:14 24:5 52:5 27:16,16 50:1 51:1 17:24 18:17 22:3 59:23 63:4 31:18 34:11 52:1 53:1 Leon (2) 22:23 23:5,6 63:18 65:9 34:13 42:16 54:1 55:1 77:3,12 23:7,15,17 looked (1) 42:18,22 56:1 57:1 let's (4) 36:17 38:8 24:7 46:3,5,9,13 58:1 59:1 19:2 33:10 39:12 40:3 looking (4) 46:14 48:23 60:1 61:1 37:25 51:13 40:10 44:6 13:25 28:16 51:13,19,24 62:1 63:1 letter (1) 44:11 64:13 62:11,17 54:9 56:4,8 64:1 65:1 71:9 lives (1) looks (3) 60:25 61:3 66:1,8 67:1 level (1) 17:6 63:7 64:6,18 62:20 65:3 68:1 69:1 10:23 LLC (46) Los (1) 72:15 76:4 70:1 71:1 liability (9) 1:8,16 2:8,9 74:23 76:10 72:1 73:1 12:21 13:20 12:19 13:21 lot (9) marriage (1) 74:1 75:1 15:16 17:15 14:3,12 15:4 9:10,15,20,21 82:15 76:1 77:1 18:10 20:5 15:16 16:14 14:20,24 married (2) 78:1,11 82:8 21:5 24:18 17:16,21 33:24,24 40:6,7 mesa (2) 24:21 18:10 20:5,9 38:20 master (1) 33:9 68:20 library (3) 20:15 21:2,7 70:4 medical (2) 49:17,19 21:10,12 M master's (2) 11:2460:5 50:13 22:14 24:3,8 M (1) 10:25 11:6 member (3) licenses (I) 24:24 25:8 6:2 matter (6) 21:6 24:25 11:14 25:23 26:7 MA (I) 61:10,13 66:19 limestone (1) 26:15,20 11:4 71:10 77:16 members (5) 34:2 28:2 30:5,24 machine (2) 78:3 82:16 21:4 24:24 limited (10) 32:2,7,9 33:2 48:4,6 MATTIIE... 25:2 73:14 12:21 13:20 34:22 50:5 Mack (1) 2:11 73:14 15:15 17:15 50:19 58:10 47:18 M1XWdl (79) mentioned (3) 18:10 20:4 66:17,20,23 Mail (I) 1:16 6:1,9,13 60:3 66:10 21:4 24:18 68:22 69:4 75: 14 7:1 8:1 9:1 68:19 24:21,22 LLC's (2) maintain (6) 10:1 11:1 merely (1) line (2) 29:14 72:20 18:21 26:2 12:1 13:1 53:24 64:24 80:6 LLP (1) 41:19 42:4 14:1 15:1 mess (1) list (1) 57:24 65:20,25 16:1 17:1 41:11 17:23 located (1) maintained — 18:1 19:1 met (1) listed (10) 54:13 36:18 20:1 21:1 77:12 19:13 20:9,18 location (1) Manhattan (... 22:1 23:1 metal (7) 53:5,20 29:22 6:23 22:24 24:1 25:1 35:10 64:9,11 54:18 57:5,7 locations (1) 23:19 33:4 26:1 27:1 64:19,21 67:17 75:10 12:16 Maritsa (5) 28:1 29:1 72:2,5 little (4) London (6) 40:23 41:5 30:1 31:1 Miami (1) 48:18.18 6:11 8:11,12 45:19,20 32:1 33:1 31:10 59:7 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324043 EFTA_00196728 EFTA01306494 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 A ffiT, NI8i5F: 03/05/2020 Page 90 mid (I) necessary (I) 1:18 3:21,21 offsite (I) paged (1) 10:11 57:17 6:3 78:17 55:12 54:22 million (1) need (1) 82:5 okay (3) paid (6) 61:24 51:16 note (2) 6:24 27:22 16:14,15,18 mind (1) needed (3) 38:9 62:23 52:7 54:3,4 55:2 67:4 14:21,23 29:3 notes (1) Old (1) Paneth (1) mine (1) neighbor (2) 65:8 2:10 57:24 25:15 35:19,25 notice (2) one-family (1) paperwork (6) Mineola (1) neighbor's (1) 43:7 61:3 67:10 12:23,24 26:3 2:10 35:8 number (3) operate (1) 51:10 57:17 misundersto... never (12) 18:17 55:9,9 75:8 66:13 30:15 18:23 19:17 numbered (1) operations (I) Paragraph (2) mobile (1) 20:6,23 23:6 54:22 75:19 27:25 29:12 65:17 24:4 28:17 - opportunity ... Paris (I) moment (2) 28:21 38:5 0 17:3 10:4 18:3 26:24 55:12 67:13 0 (4) order (3) Park (1) moments (1) 76:17 3:2 4:2 5:2 1:1944:19 2:4 67:19 New (55) 82:2 46:18 part (4) Monday (1) 1:2,3,8,12,12 object (4) organization... 5:4 35:7 37:23 40:20 1:19 2:5,5,10 3:8,11 5:5,8 32:2 75:2 Monte (2) 6:4 9:13 15:4 objection (I) original (2) part-time (1) 77:3,12 15:4,12,12 38:9 3:23 4:15 23:9 months (1) 17:9,9,12 Obviously (I) outcome (I) particular (1) 19:2 18:7,8 19:13 42:13 82:16 73:25 morning (1) 19:13 20:10 Occupancy (... outside (7) Panics (7) 6:13 20:10 21:22 43:20,22 41:15 42:3 3:4,18 4:7,13 motion (2) 21:22 23:14 occurred (2) 58:23 59:12 4:19,25 3:14 5:11 23:15 24:2 6:18 60:20 65:13,21,24 82:14 move (11) 24:21,23 ocean (1) outstanding ... passed (1) 3:9,12 5:6,9 25:5,5 26:16 50:23 14:23 38:15 15:19 20:13 26:16 29:4 offer (3) owned (7) passes (1) 20:19 21:17 29:23 31:23 11:24 60:5 8:17,19 18:23 11:5 30:21 36:10 31:23 39:24 69:16 26:19 35:14 PI' (3) 50:6 43:12,12 office (25) 37:14 47:22 16:16 33:3 moved (5) 51:8,11 2:3 28:22 ownership (5) 65:24 18:15 36:7 54:14,14,19 46:25 47:9 6:20,21,22 payroll (3) 50:10,10,13 54:19 56:15 47:10,12,15 72:19,20 29:14 30:13 multiple (2) 56:16 57:15 47:16 48:9 Oxford (2) 30:14 38:12 74:24 57:24,25 48:13 50:21 11:3,4 People (9) 71:21 82:5 65:12,14,20 14:18,20,22 N nod (1) 65:21,24 P 14:24,25 N (7) 7:4 66:2 67:17 P (5) 16:24 28:9 2:2 3:2 4:2 5:2 nonresponsi... 67:21,24 2:2,2 3/ 4:2 53:4 55:10 6:2 79:1 82:2 15:20 20:14 68:8,10 5:2 performing.., name (8) 20:20 70:23 71:4,9 page (12) 68:21 6:8,14 8:20 not-for-prof... officers (4) 52:13,17,18 period (15) 18:2,4 40:22 9:20 50:23 52:23 53:24 54:22 57:3,5 9:22,25 21:15 77:3,10 70:16 54:24 57:4 77:17 79:2 22:8,23 nearby (1) Notary (6) official (1) 80:2,6 81:2 23:13 26:14 23:5 55:20 81:13 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324044 EFTA_00196729 EFTA01306495 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 11 NYSCEF: 03/05/2020 Page 91 35:13 37:13 1:18 14:25 pleasure (1) 24:12 30:18 purchase (3) 38:8 39:9 15:3,11 9:18 39:3,17 68:8 24:16 33:3 50:12 64:13 16:24 19:12 point (3) 68:10 66:23 74:7,16 20:8,16,23 18:21 67:9 private (1) purchased (... permitting (1) 22:3,7 25:22 68:5 8:15 22:9,12,13 77:6 25:25 32:8 portion (9) Probably (2) 24:13,15 person (8) 50:12 54:12 15:20 20:14 19:4,7 26:15,21 16:20 29:17 54:17 56:14 35:7,20 proceedings ... 34:21 62:2 42:4 53:16 59:23,25 36:14 52:15 78:6 62:10,15 55:5,10 65:13,15 63:23 67:13 products (2) 66:15,16,25 59:12 77:11 68:12,15 71:13 69:14,17 67:5 personal (12) 70:18 73:13 portions (3) professional... purchasing (... 16:3,4,11,21 placement (1) 49:7 71:20,23 11:13 32:19 23:2,19 30:7 12:14 position (I) profits (1) purpose (4) 58:6 70:23 places (3) 55:19 74:12 14:11 71:6 71:5,10,13 9:16 18:17 potential (I) Project (34) 73:8 75:19 personally (1) 56:25 69:7 50:24 51:6 purposes (4) 58:16 placing (2) Power (1) 52:21,24 4:9 9:17 32:6 personnel (I) 12:14 28:9 77:6 53:12,20,22 75:18 54:23 Plaintiff (1) practice (I) 54:13,18,24 pursuant (1) phone (1) 11:25 32:8 55:3,11,15 1:19 23:12 PlaintifFs (44) practices (1) 55:24 56:11 put (3) photo (7) 13:3,5,9,13,17 53:13 56:15,20 44:8,10 68:5 42:10 63:19 17:14 19:24 predominan... 57:5,8,11 63:24 64:4 20:3 22:17 72:6 58:8,17 65:3 81:8,9 22:19 23:22 premises (II) 67:22 68:17 question (14) photograph ... 27:9,12,16 35:5,8,8 36:15 70:10,12,15 3:8,12 5:6,8 34:12,24 31:18 34:11 37:14 39:20 70:20,24 7:14,20,22 35:18 36:19 34:13,17 39:25 42:6 72:24 73:8 15:22 26:23 37:16,21,23 42:18,22 43:11 46:17 75:11,20 30:15 36:16 38:2,4,11,14 46:5,9,13,15 74:2 76:3 37:19 41:4 42:17,21,24 48:23,25 prepare (1) Projects (1) 65:18 43:3 71:18 51:13,19,24 58:10 50:22 questions (6) 71:20 52:16 54:9 prepared (3) properties (1) 6:17,19 12:15 photographs... 56:4,8 57:25 26:7 57:21,23 64:24 66:4 75:24 61:2 62:23,24 61:3,4,15 presently (1) property (9) 78:4 72:15,22 62:20 63:6 12:3 8:20,21 35:21 R 81:18 64:17 65:3 president (2) 69:24 72:10 photos (2) 71:17 76:4 51:5 70:12 76:12,14 R (2) 61:7 63:20 76:10 primary (5) 77:9 81:19 2:2 82:2 physical (1) plaintiffs (3) 8:4 9:4,11 provided (4) raiser (1) 65:20 1:6 2:4 6:15 12:18 69:24 3:7,25 4:9 5:3 73:9 picture (2) planning (2) principal (II) providing (1) rang (1) 37:12 64:15 73:21.22 15:3,11 19:12 28:11 58:22 pictures (I) Plaza (1) 20:8,16,23 public (8) read (3) 63:5 2:4 25:22,25 1:18 3:21,21 27:6,20,23 pilot (2) please (6) 54:12,17 6:4 69:11 real (5) 11:18,20 6:8,10 7:2,7 56:14 73:7 78:17 18:19 76:3,12 place (26) 7:13 24:5 prior (6) 82:5 76:14 81:19 realize (1) DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324045 EFTA_00196730 EFTA01306496 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 gfTine NYSCEF: 03/05/2020 Page 92 53:18 referred (1) 55:2 responses (1) 49:7 reason (4) 25:14 repair (1) 7:3 roots (7) 15:14,18 18:9 referring (8) 72:16 responsibilit... 38:21 39:16 74:25 6:21 8:13 28:5 repairs (2) 41:7 63:10,14,15 recall (27) 36:19 39:4 60:21 72:11 responsible ... 64:18 65:4 10:10 12:23 39:13 52:12 repeat (1) 41:14 rules (3) 14:10 16:18 52:15 36:16 responsive (1) 4:3 5:4 7:2 18:2,6 19:22 regard (1) Report (2) 30:22 RULINGS (1) 23:7 25:1 I 9:24 13:20 20:5 restarted (2) 80:5 31:14,21 regarding (3) reporter (18) 30:16.20 32:17 35:22 24:3 26:3 7:4,15 8:2 restricted (I) S 36:11 38:22 39:24 13:7,11,15 71:12 S (10) 43:24 57:22 regards (1) 22:21 27:14 resulted (1) 2:2 3:2,2 4:2,2 58:21 60:11 16:22 34:15 42:20 72:21 5:2,2 6:2 61:12 62:8 registered (I) 46:7,11 retail (1) 81:1,12 62:11,17 11:17 51:21 54:11 69:19 salaried (1) 66:16,24 regular (2) 56:6 61:6 return (11) 54:5 67:3,18 17:20 55:6 76:6 82:4 3:23 52:3,17 salary (2) receive (2) regularly (1) reports (2) 52:20 53:21 70:12 74:10 39:23 75:14 44:15 17:20 30:23 54:8 56:3,11 sale (2) received (16) related (2) represent (1) 57:10,19 69:16 76:13 13:5,9,13 74:20 82:13 6:14 75:16 Win(1) 22:19 27:11 relation (1) representing... returns (6) 60:2 34:13 42:18 17:2 4:21 37:20 26:6 54:22 Says (7) 43:19 46:5,9 relative (1) REQUESTS... 58:7,7,11,13 12:24 24:23 51:19 54:9 70:23 80:1 revenue (3) 46:25 47:13 56:461:3 relevant (1) reserved (5) 74:8,15 75:6 49:18 51:10 70:14 76:4 28:10 3:11,14 5:7,11 review (3) 53:10 recess (2) remember (... 68:16 27:2,6,8 schedule (I) 26:25 51:22 8:23 10:12 reside (1) reviewed (1) 54:23 recognize (19) 18:11 19:10 19:3 27:19 screen (1) 13:19 19:25 24:22 31:16 residence (10) right(5) 49:21 20:4 23:25 31:20 32:20 8:4 9:4,11 3:8 5:5 7:5 search (1) 34:16,19 38:15,23 18:21,24 30:25 61:11 73:14 35:10 43:2,9 48:10 51:9 21:23 22:9 rights (3) second (2) 46:14,21 59:2,21 43:25 44:3 3:7,25 5:3 37:15 57:3 52:2 56:10 64:14 77:3,8 69:24 Road (1) see (7) 63:5,18,23 77:10 resident (2) 2:10 52:18 59:12 64:19 65:2 remote (2) 18:12 67:14 Robert (1) 59:15 60:15 71:18 23:4 55:13 respect (3) 55:18 60:1763:13 record (8) remuneratio... 69:11 70:10 roof (3) 72:17 6:8,1041:13 70:14 73:11 33:13,15 aiming (1) 61:10,13 rent (4) respective (6) 49:15 43:24 63:2,3 82:10 18:24 22:6 3:4,18 4:7,13 room (9) seen (13) records (4) 31:13 65:24 4:19,25 48:2,16,20 13:22 14:2 49:23,25 50:3 rented (5) responder (1) 49:19,21,22 17:17,18 50:4 22:5,7 31:11 11:18 50:12 65:17 20:6 24:4 refer (1) 49:8 67:13 response (1) 68:3 42:24 43:19 43:14 reeumerate... 7:11 rooms (1) 43:22 52:4 56:12 63:20 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324046 EFTA_O0196731 EFTA01306497 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pt' INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 =PT 2019 03/05/2020 Page 93 76:17 shoulders (1) 60:22 62:10 10:17 11:19 state (11) selection (2) 7:10 62:11,14,18 14:10 18:2,6 1:2,18 6:4,8 73:21,23 shovel (1) 64:18 71:23 20:2 23:8 6:10 17:6 self-employe... 41:24 72:11,16 24:17 25:18 24:2,2 29:4 12:5 show (22) sidewalks (2) 26:17 31:14 57:15 82:5 sell (4) 12:25 23:21 39:17 41:22 31:21 47:3 states (8) 46:19 61:8 27:15 34:10 sign (5) 57:14,22 11:22 18:15 67:18 69:14 34:25 42:21 15:15 26:9 59:21 61:12 21:18,21.24 selling (1) 46:12 47:6 44:8 58:13 62:8 64:15 22:4 29:2,7 32:22 48:22 49:3 77:6 74:22 76:17 station (1) separate (3) 51:12,23 signature (2) 77:10,11 48:17 34:6 43:9,16 56:7 62:19 52:7,10 source (2) stayed (2) separated (I) 63:8,10 64:2 single-famil... 16:17 73:18 31:12 75:23 49:8 64:8 71:20 67:7 South (1) STIPULAT... September (... 71:23 72:2 sink (1) 2:10 3:3,17 4:6,12 6:19 8:7,25 76:9 48:18 space (2) 4:18,24 9:5,9,23 35:2 showed (1) sit (4) 69:19,21 Stipulations ... 38:25 39:17 72:14 50:11,13 speak (1) 1:19 39:21 40:4 showing (2) 65:15 71:8 28:18 stop (1) 41:2 45:22 31:17 71:17 sits (1) speakers (6) 7:19 47:25 49:5 shown (8) 48:12 12:16 14:15 stopped (2) 51:2 58:25 34:16 38:4 sitting (2) 28:11,15,16 74:25 75:4 65:22 42:10 43:2 48:20 50:7 73:18 store (I) series (2) 45:5 63:6 six (1) speaking (1) 49:25 6:17 72:14 64:16 65:2 33:14 7:15 stored (1) serve (1) shows (2) sleep (1) specific (1) 49:23 75:19 64:3,5 70:2 15:6 Street (72) service (2) Shron (1) small (2) specifically (2) 1:8,16 2:9 43:15 70:15 57:24 71:13 74:9 15:941:15 6:1122 8:11 services (2) shrug (1) snow (I) speeches (1) 9:6 15:4,12 32:18,21 7:9 41:24 9:21 17:9 19:13 set (4) shut (4) sold (12) spend (1) 20:10 21:22 67:5,7 70:19 30:17,20 31:3 46:17 61:19 19:5 22:14 24:3,8 82:9 31:3 61:21,23 speot (I) 24:13,18 seven (1) shutdown (1) 67:9 69:23 9:7 25:23 26:15 33:15 30:16 72:10 73:3 spoke (1) 26:16,20 Seventh (1) sic (1) 75:5,21 29:17 32:2,7,19,22 22:7 33:18 76:19 77:9 spoken (1) 33:2,3,8 34:8 shake (I) side (1) sole (3) 28:17 34:20,22 7:4 44:20 21:6 24:25 square (1) 35:14 36:18 sheet (1) sidewalk (30) 66:19 33:16 37:14,22,24 55:22 36:14 37:11 solely (2) stage (1) 39:13 40:3 Sheldon (2) 37:12,18,21 67:21 70:19 68:13 43:12 46:18 1:5 6:15 38:6,7,10,11 somebody (8) start (4) 47:7 49:4 short (3) 38:13,16 23:18 25:14 6:25 16:8 50:16 54:14 26:25 31:11 39:5,20,25 41:19 58:22 30:17 33:10 54:19 56:15 51:22 41:15,18,19 58:23 59:9 started (5) 61:8,9 62:2 Shorthand (I) 41:25 58:24 71:9 76:22 12:13 28:3 63:7 64:22 82:4 59:1060:17 sorry (23) 29:13 73:2,3 65:13,15,21 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324047 EFTA_00196732 EFTA01306498 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 giffne Wilr: 03/05/2020 Page 94 65:25 66:1I take (14) 50:22,24 51:5 Third (I) town (1) 66:17,20 7:4,15 13:24 52:3,21,24 57:24 70:2 68:16 70:5 17:18 20:7 53:12,18,20 this(these) (7) transfer (4) 70:19 71:21 23:23 24:5 53:22 54:13 3:10,13,19,22 76:3,12,14 71:24 72:7 27:21 41:14 54:18,24 3:24 4:8,15 81:19 72:12,20 52:5 63:4,18 55:3,11,15 Thomas (2) travel (6) 74:5 75:10 65:9 70:22 55:24 56:11 1:5 6:16 9:12,15,17 75:19 76:13 taken (5) 56:15,20 three (2) 16:23 74:19 76:20 1:18 26:25 57:5,8,11 12:25 19:8 74:20 strike (8) 51:22 62:24 58:7,17 time (57) traveling (2) 3:9,12 5:6,9 72:22 67:22 68:17 1:17 7:16 8:5 21:21 74:19 15:19 20:13 talk (2) 70:10,12,15 9:7,10,14,15 tree (47) 20:19 30:21 26:24 39:15 70:20,24 9:21,22,24 35:4,4,7,11,15 Subscribed (... talked (I) 72:24 73:8 10:7,10 11:5 35:15,17,18 78:13 71:4 75:11,20 13:25 16:9 35:18,20,23 subsequentl... talking (4) testified (1) 19:5,20,20 35:24,24 59:24 9:22 37:17 6:5 21:15 22:8 36:3,14,18 succeed (1) 38:10 40:25 testifying (3) 22:23 23:13 36:20 37:2,5 75:3 tax (21) 4:22 27:3,7 24:11,12,15 37:6,9 38:17 Suite (2) 29:4 51:18 testimony (5) 26:14,22 38:19,20,20 2:1031:10 52:3,17,20 3:10,125:7.9 27:2135:13 38:22,22 suppose (1) 53:20 54:8 82:11 36:13 37:13 39:3,5,5,16 35:3 54:22 56:3 text (I) 38:8 39:9 39:16 63:10 SUPREME ... 56:11 57:10 23:12 40:7 42:7 63:14,15 1:2 57:19 58:6,7 Thank (1) 44:5 50:12 64:6,8,9,11 sure (15) 58:11,13 78:4 52:23 56:14 64:18 65:4,4 10:11 15:17 70:2275:16 thanks (1) 59:16,18,19 65:572:2,3,5 26:8 27:20 81:15,16,17 66:9 60:11 62:16 72:6 27:23 29:5,8 taxes (6) Theresa (2) 64:12 66:25 trial (3) 29:11 31:8 28:22,23,25 82:4,20 68:24 70:7 1:15 3:15 5:11 32:13 42:2 29:6,9 70:23 thing (1) 71:16 72:9 trim (1) 53:3 57:12 technician (1) 75:25 72:19 73:17 36:23 65:1066:24 11:17 things (1) 73:17 74:7 true (2) surrounding... technology (2) 32:16 74:16 75:5 9:24 82:10 35:10 14:19,20 think (30) 75:20 try (2) SWI83X (1) telephone (4) 12:20 14:8 times (4) 7:9 15:22 6:12 45:10,11,13 15:13 17:7 18:14 45:21 trying (2) sweep (2) 45:14 24:6 26:17 45:25 74:24 15:21,24 36:1341:22 telephones (1) 32:8,933:5 timing (1) turned (I) sworn (4) 45:14 33:14 38:21 24:14 23:16 3:20 6:3 78:13 tell (12) 44:2 45:3,8 title (2) turns (1) 82:10 9:7 10:22 46:20 47:18 8:21 55:20 I 1:5 system (2) 14:11 25:4,6 47:20,24 today (3) TV (1) 44:25 50:14 37:16 50:22 49:16 50:25 16:6 27:2,7 49:20 59:8 64:5,15 55:20 59:17 told (4) two (6) - T 64:16 65:7 60:3,10,11 59:9,19 60:13 8:9 19:8 34:9 T (10) ten (3) 60:1261:11 60:18 42:14 43:6 3:2,2 4:2,2 5:2 16:5,6,12 64:21 66:13 top (2) 64:24 5:2 81:1,12 Terramar (3... 68:9 47:20,23 two-family (6) 82:2,2 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324048 EFIA_O0196733 EFTA01306499 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 law: 03/05/2020 Page 95 43:25 44:3 varies (1) 25:11 32:17 13:5,18 66:11,13 54:23 42:7 59:19 x(7) 31:18 81:3 67:2,5 vehicle (1) 74:23 1:4,10 6:2 10 (6) type (5) 14:13 West (I) 47:13 79:1 51:13,19,24 14:17,22 15:2 venue (2) 25:5 81:1,12 52:16 58:2 71:8 72:16 73:21,23 wholesale (1) 81:15 Typically (1) verbally (2) 69:2 I 10:07 (1) 45:20 7:3,11 wide (I) Yeah (1) 1:13 version (1) 33:24 16:13 100017 (1) U 48:25 witness (10) year (6) 57:25 U (3) violations (1) 6:3,24 7:6,8 19:2 31:5,7,15 10004 (1) 3:2 4:2 5:2 39:23 7:12 15:21 31:22 72:9 2:5 U.S (3) 15:24 51:15 years (5) 11 (5) 10:7.9 11:23 W_ 82:8,11 16:5,6,12 30:2 14:8 29:12 understand ... W (1) witness(es) (2) 32:17 54:7,9 81:16 7:20,22 63:21 6:2 3:20 4:22 yellow (1) 11:47 (1) 64:23 waived (1) woke (1) 52:16 78:7 understandi... 4:16 68:24 York (53) 114 (7) 73:12 waiver (3) word (1) 1:2,3,8,12,12 35:19 39:13 understood ... 3:14,25 5:10 20:7 1:19 2:5,5,10 39:14 64:22 7:23 walk (4) words (1) 6:4 9:13 15:4 71:21,24 unemployed... 44:11,15,19 28:12 15:5,12,12 72:6 21:14 59:12 work (33) 17:9,9 18:7,8 11501 (1) Uniform (1) walked (2) 9:19,20 16:7 19:13,14 2:10 5:4 44:13,13 16:20 21:11 20:10,10 116 (71) United (6) want (5) 21:13 23:16 21:22,23 1:8,16 2:9 11:22 21:17 7:2 26:24 63:4 28:4,5,13 23:14,15 6:22 8:11 9:6 21:23 22:4 65:8 73:11 29:22 30:4,6 24:2,21,23 15:11 17:8 28:25 29:6 wanted (2) 30:18 38:3,5 25:5,5 26:16 20:9 21:22 unusual(1) 28:8 71:8 38:7,15,16 26:16 29:4 22:12,13,13 32:10 was(were) (1) 38:18,21 31:23,23 24:3,8,12,18 upper (1) 3:22 39:2,4 55:3,4 39:24 43:12 25:23,24 63:23 wasn't (3) 55:7,11,12 43:12 51:8 26:14,15,20 use (11) 15:6 68:21 65:17 68:21 51:11 54:14 32:2,7,19,22 49:20 50:6 75:3 72:21 74:2,5 54:14,19,19 33:2,3,8 34:7 51:15 67:10 watch (1) worked (14) 56:16,16 34:20,22 67:21 68:10 49:20 18:5 21:12 57:15,24,25 35:13 36:17 68:16 70:19 water (1) 23:16 25:15 71:21 82:5 37:14,22,24 70:24 71:5,9 36:25 29:25 30:3,7 40:3 43:11 useless (1) way (4) 41:5 52:21 46:17 47:7 75:4 22:2 34:25 52:24 54:24 -- 49:4 50:15 utilize (3) 64:12 82:15 55:5 73:25 54:13,18 32:18,21 week (8) 74:23 06 (1) 56:15 61:7,8 49:19 40:17,19 working (5) 36:11 62:2 63:7 utilized (1) 52:21 53:9 16:8 55:23 08 (1) 64:3,22 4:9 53:10,11 57:7 74:25 21:16 65:13,14,21 55:23 57:7 75:2 65:25 66:11 V weeks (3) 1 wouldn't (1) 66:16,19 valued (1) 19:8,8,8 1 (7) 55:7 68:15 70:5 44:2 went (5) 1:1 9:23 13:3 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324049 EFTA_O0196734 EFTA01306500 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 Ar ) ffiV5D, NYSCEF: 03/05/2020 Page 96 66:16,19 2 9:5,8,9,23,23 3116 (1) 6,000,000 (2) 68:15 70:5 2 (6) 17:15 19:9 4:3 33:5,6 70:18 71:21 2:1,10 13:3,9 19:12 28:23 3117 (1) 6,500 (I) 71:24 72:12 17:14 81:4 31:22 35:2 4:3 33:18 72:20 74:5 2-23-15 (2) 38:25 39:17 32nd (1) 60 (4) 75:10,18 13:8 81:4 39:21 40:4 2:4 52:21 55:23 76:13,20 20 (I) 40:25 41:3 33139 (1) 57:7 81:18 116A (2) 32:16 41:20 44:12 31:10 6000 (1) 15:4 19:13 200 (1) 45:22,24 34 (I) 33:18 12 (3) 2:10 47:24,25 81:8 65th (72) 56:4,8 81:17 2000 (10) 49:5 50:2 1:8,16 2:9 13 (3) 51:3 55:15 4 6:22 8:11 9:6 21:16 22:12 81:3,4,5 24:11 26:22 56:22 57:10 4 (5) 15:4,11 17:8 I3A (4) 62:14 66:15 58:25 65:12 4:1 22:17,19 19:13 20:10 61:4 62:20 67:9 69:23 65:22 71:2 23:22 81:6 21:22 22:14 63:6 72:15 70:7 72:9 2016 (15) 4/5/19 (2) 24:3,8,13,18 13A-13E (1) 2001(I) 17:8,11 18:13 22:18 81:6 25:23 26:15 81:18 16:9 19:3,6 20:4,8 42 (1) 26:16,20 I3B (I) 2002 (I) 61:11,22 81:9 32:2,7,19,22 63:18 16:9 67:10 69:23 44 (I) 33:2,3,8 34:7 13C (1) 2005 (1) 70:8 72:10 6:11 34:20,22 64:5 36:11 75:6,21 46 (2) 35:13,19 13D (1) 2009 (I) 2017 (7) 81:10,14 36:18 37:14 64:17 21:16 29:14 30:11 475 (1) 37:22,24 13E (3) 2010 (11) 30:13,18 25:5 39:13 40:3 61:4 65:3 14:8 28:3,8 68:24 69:3 43:12 46:17 5 72:15 29:12 68:8 73:3 47:7 49:4 14 (6) 2019 (2) 5 (6) 50:16 54:13 68:10 69:6 5:1 27:12,16 61:22 67:10 69:11 70:25 1:13 78:15 54:19 56:15 73:3 76:4,10 22 (1) 54:22 61:16 61:8,8 62:2 74:16 75:21 81:7 81:19 2011 (2) 81:6 63:7 64:22 15 (2) 221 (I) 50,000 (1) 65:13,14,21 50:25 73:2 61:24 30:24 61:24 2012 (5) 5:4 65:25 66:11 159225/2010... 23 (I) 51 (1) 66:16,19 50:25 51:18 81:15 1:10 52:3 54:12 52:25 68:16 70:5 16 (2) 25 (I) 535 (1) 70:19 71:21 81:15 1:11 30:24 31:9 2013 (12) 33:24 71:24 72:7 17 (1) 25th (1) 54 (1) 72:12,20 30:20 54:8,17 81:16 47:13 55:24 68:20 10:6 74:5 75:10 17.3 (1) 27 (I) 56 (I) 75:19 76:13 69:3,6,12 81:17 47:13 74:17 75:2,5 81:7 76:20 17007 (1) 59th (I) 66 (1) 81:16 22:7 2:12 3 79:5 2014 (8) 1961 (1) 13:20 30:24 3 (8) 685 (1) 6 10:6 31:15,19 3:1 13:3,13 57:24 19:24 20:3 6 (8) 1991 (2) 56:3,11,20 34:11,13,17 21:19,20 47:13,14 7 81:17 37:22 45:5 1st (1) 2015 (36) 81:5 7(3) 3-22-16(2) 71:17 79:3 42:18,22 81:9 9:8 6:19 8:8,25 13:12 81:5 81:8 70 (1) DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324050 EFTA_O0 196735 EFTA01306501 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 AIFEETVV; Nyai5F: 03/05/2020 Page 97 31:10 76(2) 79:4 81:19 8(7) 465J 3,15 47:14 48:25 52578150 9 9(13) 1:13 6:199:9 9:23 27:25 38:25 39A 7 40:4 46:9 48:23 51:2 58:25 81:14 9-18-14(2) 13:4 81:3 90s(2) I0A 1J I 92(1) 8:3 93(1) 8:3 9th(2) 35:2 39:21 DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00324051 EFTA_O0196736 EFTA01306502 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 RECEIVED NYSCEF: 03/05/2020 CORRECTION / ERRATA SHEET klEXITAS RwletteroftheUmhIbeSpirftof5imace. being duly sworn, deposes and says: I have reviewed the transcript of my deposition / hearing taken on . The following changes are necessary to correct my testimony. CASE CAPTION: Page: Line: Should read / Corrected Testimony: Reason for Change Sworn to before me this Testimony Deposition / Hearing Witness: Day of X NOTARY PUBLIC Print: Lexitas • Court Reporting • 800-788-0166 Administrative Offices • 100 Merrick Road — Suite 320W • Rockville Centre, NY 11570 SONY_GM_00324052 EFTA_00196737 EFTA01306503