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Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 2 of 10 Yet during her deposition, Defendant refused to answer any questions that she construed as having something to do with “consensual adult sex.”” Defense counsel supported that position that “frankly, [that’s] none of your business and I instruct the witness not to answer.” See Declaration of Sigrid S. McCawley (“McCawley Decl.”’) at Exhibit 1, Tr. of Maxwell Depo. (Apr. 22, 2016) at 21, The result was that at a number of points throughout her deposition, Defendant refused to answer questions about subjects integral to this lawsuit, including questions about what the alleged “massage therapists” were doing at Jeffrey Epstein’s house and the sexual nature of those massages. For example, Defendant refused to answer questions about whether she had given Jeffrey Epstein a massage: Q. Have you ever given Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, /'’m going to instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition. MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions. MR. PAGLIUCA:; | disagree and you understand the bounds that I put on MS. McCAWLEY: No, I don't. I will continue to ask my questions and you can continue to make your objections. Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female? MR. PAGLIUCA: Objection. Do not answer that question. Again, to the extent you are asking for some sort of illegal activity as you've construed in 2