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Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 3 of 14 Defendant Ghislaine Maxwell submits this Reply to Plaintiff's Opposition (“Response’’) to Motion to Reopen Deposition of Plaintiff (“Motion”), and as grounds therefore states as follows: INTRODUCTION’ Plaintiff concedes the reopening of her deposition based on (a) the late production of records concerning Plaintiffs medical and mental health treatment, (b) her unjustifiable refusal to answer questions related to statements the media “got wrong,” (c) material edits to her deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed employment records and thus it should be deemed admitted. Apparently, she still contests questions regarding other items not disclosed until after her deposition, including (a) iCloud and Hotmail emails, (b) school records from Forest Hills High School, Wellington High School and Survivors Charter school, and (c) witnesses newly identified in her Third and Fourth Revised Rule 26 disclosures. There is no legally principled reason to exclude these topics during Plaintiff's reopened deposition and Ms. Maxwell should be permitted to examine Plaintiff based on this information produced after her deposition although requested before. The other limitations proposed by Plaintiff are not appropriate. Due to the quantity of documents and the number of topics, two hours will be insufficient to appropriately inquire. Moreover, Plaintiffs deposition should be in person; she chose to move to Australia from Colorado during the pendency of this case and has been in the US for weeks attending witness depositions and other litigation matters by her own choosing. Deposition by videoconference will be extremely cumbersome to accomplish given the hundreds of pages of documents to be ' Defendant conferred with counsel for Plaintiff regarding this Motion prior to its filing. By email of May 8, 2016, Mr. Pagliuca requested conferral regarding Plaintiff's refusal to answer questions at her deposition. That conferral was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition. 1