Giuffre_Maxwell_Batch3_p00109.png

——_—_______Case_1:15-cv-07433-LAP_ Document 1327-9 Filed 01/05/24 Page 11 of 21 Furthermore, privacy concerns are alleviated by the protective order in this case, drafted by Defendant. Defendant is ordered to answer questions relating to Defendant’s own sexual activity (a) with or involving Jeffrey Epstein (“Epstein”), (b) with or involving Plaintiff, (c) with or involving underage females known to Epstein or who Defendant believed or intended might become known to Epstein, or (d) involving or including massage with individuals Defendant knew to be, or believed might become, known to Epstein. Defendant is also directed to answer questions relating to her knowledge of sexual activities of others (a) with or involving Epstein, (b) with or involving Plaintiff, (c) with or involving underage females known to Epstein or who Defendant believed were known or might become known to Epstein, or (dad) involving or including massage with individuals Defendant knew to be or believed might become known to Epstein.! The scope of Defendant’s answers are not bound by time period, though Defendant need not answer questions that relate to none of these subjects or that is clearly not relevant, such as sexual activity of third-parties who bear no knowledge or relation to the key events, individuals, or locations of this case. 1 Each of the aforementioned lists are disjunctive. 10