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Case 1:20-cr-00330-AJN Document136 Filed 02/04/21 Page 16 of 27 2. The Second Question: “List all of the people under the age of 18 that you interacted with at any of Jeffrey’s properties?” The second “question” was equally improper. First, this is not a question. Rather, it is a demand to do something, make a list. Fed. R. Civ. P. 30(a)(1) limits a deposition to “oral questions.” The question was grossly ambiguous: who was “Jeffrey”; what were “Jeffrey’s properties;” to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been “under the age of 18”; and what did “interact with” mean? Again, the Government selectively omits objections, context, and relevant colloquy. This series of questions begins at page 382 of the April 2016 deposition: — | — DOJ-OGR-00002425