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Case 1:20-cr-00330-AJN Document136 Filed 02/04/21 Page 10 of 27 you're talking about” and an inability to “list” (sixteen years after the fact) “all of the people under the age of 18” that she interacted with at “any of Jeffrey [Epstein’s] property.” Because Ms. Maxwell had refused, on advice of counsel, to answer irrelevant questions at that April 2016 deposition that concerned her consensual adult sexual activity with others including Mr. Epstein, Ms. Giuffre’s counsel sought a second deposition a short time later. Ms. Maxwell opposed the second deposition and argued that her private adult consensual sexual activity had no relation to the defamation lawsuit. Ultimately, i Ms. Maxwell sat for this second deposition on July 22, 2016. The testimony was marked “Confidential.” Again, plaintiff vastly exceeded the bounds of the permitted topics, including in the questions that are quoted in Count 6 of the Indictment. The excerpts reproduced in the Indictment, as with Count 5, similarly ignore the questions, answers, and objections that occurred over the course of the deposition, as well as other objections in the case concerning the relevant time frame for discovery purposes. DOJ-OGR-00002419