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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 13 of 17 In sum, Defendant refused to answer important questions relating to the following topics that were authorized by this Court’s Order: (1) Defendant’s information relating to and knowledge of the circumstances of Johanna Sjoberg performing massages and sex acts upon Epstein; (2) Defendant’s information relating to and knowledge of the circumstances relating to the abuse of Maria Farmer and her sister by Defendant and Epstein; (3) Defendant’s information relating to and knowledge of any lists or records of girls who gave “massages” to Epstein; (4) Defendant’s involvement with messages (or related documents) showing Defendant’s knowledge of, and involvement in, the scheduling of underage girls for massage and sex with Epstein, and any destruction of evidence related to these messages (or related records); (5) foundational questions that were necessary precedent to asking questions authorized by this Court’s Order; and (6) all related questions that arise out of any response Defendant provides within the parameters of the Court’s June 20, 2016, Order. DISCUSSION The Court should compel Ms. Maxwell to answer questions in the topic areas where she refused to answer during her recent deposition. Topics | - 4 above are central parts of this case, and Topics 5 and 6 link directly to central parts of this case. Ms. Giuffre, and now other knowledgeable witnesses, have explained and testified that Defendant not only had knowledge of Epstein’s massages and sexual activity with others, but she actively facilitated the sexual massages through recruiting young females and underage girls for the purpose of “massage” and sexual activity. And proof that Defendant both had knowledge of, and was involved in, these schemes and encounters, will further help prove that Defendant’s statements to the press that Virginia’s allegations were “obvious lies” was itself an obvious lie. 13