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Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 12 of 28 e Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring them to Epstein. Jd. at 244-46. e Whether Defendant knew Epstein had a sexual preference for minors. Jd. at 251-53. e Whether Defendant knew that asked girls to come over to see Epstein for purposes of sexual massage. e Whether Defendant could recall secing and Epstein together. a. e Whether Defendant was aware of any interstate or international transportation of women, aged 18 to 28, for purposes of having sex with Epstein where they would receive compensation. Jd. at 278-79. e Whether Defendant could recall anything about a puppet or caricature of Prince Andrew in Epstein’s home when Prince Andrew was there, including whether Ms. Giuffre was sitting on Prince Andrew’s lap with the puppet or caricature. Jd. at 289-93. e Whether Defendant could remember entering any telephone numbers into a contact book maintained by Epstein. Jd. at 320-22. e Whether a document with Epstein’s contacts (including “massage” contacts) was located on Defendant’s computer. Jd. at 331-34. e Whether, if Alfredo Rodriguez said that Defendant had knowledge that underage girls were coming over to Epstein’s Florida mansion for purposes of sex, that would be a true statement. Jd. at 329-30. e Whether Defendant could recall any representative of hers informing the press that Ms. Giuffre committed grand theft. Id. at 344-45. e Whether Defendant knew what her press agent, Ross Gow, was referring to when he talked in an email about “helpful leakage.” Jd. at 349-50, 406. e Whether Defendant could recall interacting with anyone, other than Ms. Giuffre, under the age of 18 on any of Epstein’s properties. Jd. at 384. e Whether Defendant had discussed with Prince Andrew any of the details of Ms. Giuffre’s allegations against him. Id. at 400. Because Defendant refused to answer those questions, Ms. Giuffre needs to depose other witnesses who have the requisite knowledge to testify concerning those issues.