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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 161 of 239 Q. I will ask that question if you want, but I was focusing on people other than Mr. Epstein right now. A. I don’t give massages. Q. Let's just tie that down. It is your testimony that you’ve never given anybody a massage? A. Lhave not given anyone a massage. Q. You never gave Mr. Epstein a massage, is that your testimony? A. That is my testimony. Q. You never gave [Minor Victim-2] a massage is your testimony? A. Inever gave [Minor Victim-2] a massage. (Ex. 11 at 112:17-113:12). The defendant argues that these questions were fundamentally ambiguous because the deposition elsewhere discussed both sexual and professional massages. It was unclear, she explains, what kind of massage the questioner meant. (Def. Mot. 4 at 17.) The defendant’s argument is, yet again, misguided. This line of questioning used broad language, and at no point during this set of questions did Giuffre’s counsel suggest that the questions were limited to sexual or professional massages. Cf Lighte, 782 F.2d at 376 (concluding that the word “you” was ambiguous when the prior two questions asked about the defendant “as an individual” and then switched “without indication” to the defendant “as trustee”). The defendant’s answers were unequivocal, with no expressions of confusion or internal contradictions. Cf Markiewicz, 978 F.2d at 809 (explaining that a question was ambiguous as to whether it asked about the deponent’s personal or professional capacities, in light of the deponent’s confusion in the next questions). A properly instructed jury could conclude that the defendant meant what she said: she never gave anyone a massage, including Epstein and Minor Victim-2. 134 DOJ-OGR-00003095