DOJ-OGR-00018780.pdf

Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 182 of 264 1620 LC7Cmax6 Carolyn - cross 1 Q. I'm sorry. I didn't hear the answer. 2 A. Correct. 3 Q. The complaint didn't mention Ms. Maxwell's name; correct? 4 A. Correct. 5 Q. The complaint was 91 pages with 209 paragraphs. Do you remember that? 6 A. Yes. 7 Q. And not one paragraph had the word "Maxwell" in it; correct? 8 A. Correct. 9 10 MR. PAGLIUCA: I would like to show the witness and 11 the Court first Exhibit C4. I provided the government a copy 12 of this exhibit. 13 14 THE WITNESS: Is it in the binder? 15 MR. PAGLIUCA: It's in the smaller binder. We can put 16 it on the screen, if that's easier. 17 THE WITNESS: What's the number? 18 MR. PAGLIUCA: C4. 19 THE WITNESS: Okay. 20 THE COURT: Question. 21 MR. PAGLIUCA: Yes, your Honor. 22 BY MR. PAGLIUCA: 23 Q. This complaint was filed by Mr. Willits on your behalf in 24 state court. Do you recall that? If you look at page 3, 25 Mr. Willits' signature is there. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018780