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Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 13 of 14 2. Any question she was instructed not to answer regarding: a. Inaccurate statements attributed to her in the press; b. Her communications with law enforcement about Ms. Maxwell; 3. Any changes to her deposition testimony as reflected on her errata sheet. Ms. Maxwell asks the Court to deny Plaintiffs request that the reopened deposition be limited to two hours or occur via remote means. Finally, Ms. Maxwell requests costs incurred in bringing this Motion based on counsel’s improper instructions not to answer relevant and non- privileged questions. Dated: July 8, 2016 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10™ Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Ghislaine Maxwell 11