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Case 1:20-cr-00330-AJN Document136 Filed 02/04/21 Page 14 of 27 Cir. 1978) (deciding prosecutor's question whether accused “handled” checks too ambiguous; accused could justifiably infer “handled” meant “touched”). Moreover, “a perjury conviction must rest on the utterance by the accused of a false statement; it may not stand on a particular interpretation that a questioner places upon an answer.” Id. at 374 (citing Bronston, 409 U.S. at 360). “[A]ny special problems arising from the literally true but unresponsive answer are to be remedied through the ‘questioner's acuity’ and not by a federal perjury prosecution.” Bronston, 409 U.S. at 362. “The burden is on the questioner to pin the witness down to the specific object of the questioner's inquiry.” /d. at 360. B. Count Five 1. First question: “Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know.” This was an improper question for many reasons and was, accordingly, the subject of well-founded objections. The question asked for Ms. Maxwell to understand and comment on Epstein’s state of mind; any answer would either have been made without personal knowledge under Fed. R. Evid. 602 or have been hearsay. Ms. Maxwell’s answer—“I don’t know what you are talking about” — was completely understandable, particularly given the context. At the time of the deposition, Epstein had pled guilty to a state indictment in Florida, and the facts and circumstances surrounding the Palm Beach Police department investigation were widely known and discussed in the deposition. Ms. Maxwell’s answer, “I don’t know what you are talking about,” was simply a true statement that the question lacked clarity. The Government has selectively, and misleadingly, omitted testimony and objections to questions that place Ms. Maxwell’s statement in context. The complete exchange: DOJ-OGR-00002423