This document is a page from a court filing (Case 1:20-cr-00330-PAE, filed April 16, 2021) containing excerpts of a deposition. The defendant (implied to be Ghislaine Maxwell) testifies that she was unaware of Jeffrey Epstein having sexual activities with anyone other than herself, a 'blond,' and a 'brunette' during the 1990s and 2000s. The document includes legal analysis arguing that the defendant's statement '[w]hen I was with him' referred strictly to moments of sexual acts rather than the duration of their relationship.
| Name | Role | Context |
|---|---|---|
| Mr. Epstein | Subject of inquiry |
Jeffrey Epstein; subject of questions regarding sexual activities.
|
| The Defendant | Witness/Accused |
Likely Ghislaine Maxwell (based on case number 1:20-cr-00330-PAE); providing testimony regarding knowledge of Epstein...
|
| Mr. Pagliuca | Attorney |
Lawyer raising objections during the deposition.
|
| Unidentified Blond | Participant |
Identified as having been involved in three-way sexual activities with Epstein and the defendant.
|
| Unidentified Brunette | Participant |
Identified as having been involved in three-way sexual activities with Epstein and the defendant.
|
| Name | Type | Context |
|---|---|---|
| Department of Justice (DOJ) |
Inferred from Bates stamp 'DOJ-OGR'.
|
"I wasn't aware that he was having sexual activities with anyone when I was with him other than myself."Source
"Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you?"Source
"That is my testimony, that is correct."Source
"In the defendant’s telling, the phrase “[w]hen I was with him,” refers not to the duration of the defendant’s relationship with Epstein, but instead to only those moments when she was in the act of having sex with Epstein..."Source
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