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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 10 of 27 Duplicative Topic of Questioning (Exhibit) ition (Exhibit Dp osition 47:15-49:18; Her knowledge of Sara Kellen, when she last 56:21-57:11; spoke to Ms. Kellen, what Ms. Kellen’s job was, | 254:25-256:8; 117:14-118:9; and her knowledge of sexual relations between 328:21-329:6; 125:2-126:21 Ms. Kellen and Mr. Epstein 396:4-21; 411:14-412:22 329:7-330:12; 331-9-335-10 129:15-132:6 Her interactions with Alfredo Rodriguez 379:22-380:18; Her knowledge concerning Jean Luc Brunel’s 99:14-21; 150:6-17 sexual activities or interaction with Mr. Epstein | 116:19-117:3; 166:21-167:23 Her knowledge of the identities of a list name 312:15-334:8 179:16 -184:15 titled “Massage — Florida” from an address book marked in the first deposition and discussed at length THE QUESTIONS I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERED REQUIRES DENIAL OF THE MOTION Plaintiff broadly, and inaccurately, claims now that at her second deposition, Ms. Maxwell “refused to answer many questions” related to sexual activity or “refused to answer questions about subject integral to this lawsuit.” Motion at 3-4. This assertion is patently dispelled by a review of the second deposition transcript which is 193 pages long. Pagliuca Decl., Ex. D. The deposition began at 9:04 a.m. and concluded at 2:51 p.m. The total time Ms. Maxwell testified in this deposition was 4 hours and 52 minutes for a total combined deposition 8