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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 4 of 27 of defendant Ghislaine Maxwell. The harassing, extended, repetitive, cumulative and redundant continued deposition of Ms. Maxwell should be concluded. FACTUAL BACKGROUND On April 22, 2016 Plaintiff deposed Ms. Maxwell for a full seven hours. The transcript of that deposition is 418 pages long. Ms. Maxwell did not assert any privilege against self- incrimination and was questioned extensively about, among other things: her relationship with Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors, non-consensual sex, sex involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein, sex involving the Plaintiff and Ms. Maxwell, sex involving the Plaintiff, Ms. Maxwell and Mr. Epstein. She was asked questions about whether she recruited girls for Ms. Epstein to have sex with, her knowledge of Ms. Epstein’s sex with a number of people. She was asked questions about “sex toys,” pornographic images, child pornography, and nudity at Mr. Epstein’s house. Ms. Maxwell answered these questions, and many others, to the best of her ability. See Pagliuca Decl., Composite Exhibit C (Transcript of (First) Deposition of Ghislaine Maxwell on April 22, 2016). During her first deposition, Ms. Maxwell was freely questioned and testified about the following: e She never had a sexual encounter with Plaintiff, ever. /d. at 76:3-11. e She never saw Plaintiff massage Mr. Epstein. Jd. at 75:12-24. e She never saw Jeffrey Epstein and Plaintiff in a sexual situation. Jd. at 75:23- 76:1. e She did not have a set of outfits for Plaintiff to wear. Jd. at 69:1-24, and again at 117:4- 15. e She had no knowledge of any non-consensual sex acts involving Mr. Epstein. Jd. at 55:5- 15. e She never had non-consensual sex with anyone. /d. at 62:19-20 & 63:23-25.