Giuffre_Maxwell_Batch3_p00318.png
Extracted Text (OCR)
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.
Extracted Information
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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 |