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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 4 of 17 points throughout her deposition, Defendant refused to answer questions about subjects integral to this lawsuit, including questions about a student, Joanna Sjoberg, who Defendant recruited from her school to give massages to, and have sex with, Jeffrey Epstein under the guise of hiring her to answer phones. For example, Defendant refused to answer questions about recruiting Ms. Sjoberg for sex with Epstein: Q. So is it fair to say that Johanna was initially hired to answer telephones, according to your testimony? MR. PAGLIUCA: This has already been testified to Mr. Boies. We are repeating testimony now. MR. BOIES: I think in the context of the witness’ answers, these are fair questions. Now, I’ve asked you before, if you want to instruct her not to answer, if you want to go to the judge, we are happy to do that, but I would suggest in the interest of moving it along, that you stop these speeches. MR. PAGLIUCA: You are not moving it along is the problem, so maybe we should call the court and get some direction here, because I am not going to sit here and rehash the testimony we already gave. MR. BOIES: That’s fin[e]. [At this point a telephone call was placed to Judge Sweet’s chambers]. See Schultz Decl. at Composite Exhibit 7, Excerpts from July 22, 2016, Deposition of Ghislaine Maxwell at pg.78:17-79: 14. MR. BOIES: So how did it happen, Ms. Maxwell, that Joanna, who had been hired to answer the phones, ended up giving massages to you and Mr. Epstein. MR. PAGLIUCA: I’m going to instruct you not to answer the question. This has been previously , the subject of your former deposition, it doesn’t fall into any of the categories ordered by the court, and so you don’t need to answer that. Id. at pg.81:15-25. Defendant’s counsel’s instruction not to answer was improper. This Court’s Order stated: “Defendant is also directed to answer questions relating to her knowledge of sexual activities of others . . . involving or including massage with individuals Defendant knew to be or believed