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Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 3 of 10 connection with this case I don't have any problem with you asking that question. To the extent these questions involve consensual acts between adults, frankly, they're none of your business and J will instruct the witness not to answer. MS. McCAWLEY: This case involves sexual trafficking, sexual abuse, questions about her having interactions with other females is relevant to this case. She needs to answer these questions, MR. PAGLIUCA: I'm instructing her not to answer. MS. McCAWLEY: Then we will be back here again. See McCawley Decl. at Exhibit 2, Tr. of Maxwell Depo. (Apr. 22, 2016) at 19-22 (emphasis added). Defendant’s participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and how to turn the massage into a sexual event. Obviously, proof that Defendant had previously massaged Epstein — include massages with sexual component — would provide important corroboration for Ms. Giuffre’s testimony at trial. And proof that Defendant was involved in massages will further help prove that statements to the press that Virginia’s allegations were “obvious lies” was itself an obvious lie. As another example, Defendant refused to answer questions about her knowledge that Johanna Sjoberg was hired to work for Epstein and provided massages. In the police report, Johanna admitted that Maxwell recruited her to work for Epstein. See McCawley Decl. at Exhibit 3, Giuffre000076-77 (police report indicating that Johanna was recruited by Maxwell). Yet during Defendant's deposition, she refused to answer questions regarding Johanna Sjoberg. Q. Do you know what tasks Johanna was hired to performance? A. She was tasked to answer telephones. Q. Did you ever ask her to rub Jeffrey's feet? ... A. | believe that I have read that, but I don't have any memory of it.