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Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 10 of 23 The district court granted the motion. In requiring Maxwell to answer highly intrusive questions “relating to [her] own sexual activity” and “her knowledge of the sexual activity of others,” the court held that Maxwell’s “privacy concerns are alleviated by the protective order in this case.” Secure in the belief that the Protective Order would be honored, Maxwell appeared at a second deposition, in July 2016, and answered hundreds of pages worth of questions about Jj SS 2 ES From the very first question, Maxwell discussed [las OO —CSCSCSC‘C(CSCs ees. She was asked ee OO —“CSCSCSCSC‘i‘ i —CsisSCSC‘CiésSS She was asked SCC‘ 7} Count Six of the superseding indictment alleges that Maxwell provided false testimony when she testified during her July 2016 deposition that: (1) she could not recall whether sex toys or devices were used in sexual activities at Epstein’s Palm Beach house; (2) she did not know whether Epstein possessed sex toys or devices used in sexual activities; (3) she wasn’t aware that Epstein was having sexual activities with anyone other than herself when she was with him; and (4) she never gave anyone, including Accuser-2°, a massage. 3 The indictment refers to the accusers as Minor Victim-1, Minor Victim-2, and Minor Victim-3. We will refer to them as Accuser-1, Accuser-2, and Accuser-3. 5 DOJ-OGR-00002357