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Giuffre_Maxwell_Batch3_p00318.png

Source: GIUFFRE_MAXWELL  •  Size: 293.4 KB  •  OCR Confidence: 94.9%
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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 12 of 27 (S.D.N.Y. Sept. 9, 1994) (permitting reopening of deposition only if party could specifically identify areas of inquiry previously foreclosed). To the extent Plaintiff has not identified specific questions that Ms. Maxwell was instructed not to answer she has waived any issue related to the questioning. Il. THE REQUESTED TOPIC AREAS ARE CUMULATIVE, DUPLICATIVE AND NO GOOD CAUSE EXISTS FOR PERMITTING ADDITIONAL DEPOSITION TIME Plaintiffs proffered “topic areas” that she would like to re-open the deposition to cover — again — makes clear that what she is asking for is additional time — in excess of the almost 12 hours she has already had — to ask questions that have already been answered. This is impermissible under Rule 30(d)(1) which prohibits depositions in excess of 7 hours seeking the type of duplicative and cumulative testimony Plaintiff seeks. The only testimony cited in the Motion are instances in which Ms. Maxwell had already fully testified on the topic area. First, she cites questions concerning Johanna Sjoberg, a witness who has been deposed in this case. What Plaintiff ignores is that Ms. Maxwell had already been fully examined concerning her knowledge about Ms. Sjoberg and answered every question, with the exception of a single questions regarding adult consensual sexual activity which was answered in the second deposition. See Pagliuca Decl., Ex. C at 59:7-63:16; 286:23-293:13; 307:6-312:12 & Ex. D at 77:24 — 78:6 (“Q. Did Mr. Epstein, insofar as you believe, engage in sexual activities with Johanna? A. I would not know. I would say no. Q. Did you engage in sexual activities with Johanna? A. No.”). Despite this, leeway was given, and 5 pages of repeated testimony concerning Ms. Sjoberg commenced and was permitted until the duplicative nature of the testimony was simply too much. See Pagliuca Decl., Ex. D at 74:2-78:19.

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Filename Giuffre_Maxwell_Batch3_p00318.png
File Size 293.4 KB
OCR Confidence 94.9%
Has Readable Text Yes
Text Length 1,939 characters
Indexed 2026-02-04 12:39:50.769903