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Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 5 of 10 Here again, this information is critical to the case. Among other things, these questions are designed to show a modus operani (“M.O”) for Epstein and Maxwell — specifically, how they recruited for a non-sexual massage than converted the massage into sexual activities. One last illustration comes from Defendant's refusal to answer about her knowledge of Epstein’s sexual interests during massages: Q. Does Jeffrey like to have his nipples pinched during sexual encounters? MR, PAGLIUCA: Objection to form and foundation. A. I'm not referring to any advice on my counsel. }'m not talking about any adult sexual things when I was with him. Q. When Jeffrey would have a massage, would he request that the masseuse pinch his nipples while he was having a massage? A. I'm not talking about anything with consensual adult situation. See McCawley Decl. at Exhibit 5, Tr. of Maxwell Depo. (Apr. 22, 2016) at 82. While Epstein himself might also provide answers to these questions, it appears likely that he will assert his Fifth Amendment privilege regarding his sexual activities. Accordingly, Ms. Giuffre must pursue questioning of Maxwell to obtain information on this subject. Here again, information about Epstein’s sexual idiosyncrasies will provide important corroboration to Ms. Giuffre’s testimony that she had sexual interactions of an identical nature with Epstein. These refusals are not an isolated instance. Instead, similar refusals to answer questions occurred repeatedly throughout the deposition. See, e.g., McCawley Decl. at Composite Exhibit 6. 52-55; 64-65; 82; 92-93; 137-38; 307-09. The Court should compel Defendant to answer all these questions. In addition to the specific points made above, the “big picture” here reveals how vital such discovery is. At the core of Ms. Giuffre’s allegations is the allegation that Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually tried