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Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 8 of 27
The continued deposition was expressly limited to the above eight categories, and the
Court instructed that Ms. Maxwell “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 key events, individuals, or locations of this case.” Order of June 20,
2016 at 10 (Doc. # 264-1). Presumably the Court did not authorize repetitive questioning about
topics that had been asked and answered in the prior deposition.
Ms. Maxwell had already been subjected to, and fully answered, questions related the
majority of the 8 topics in her first 7-hour deposition. Questions related to topics 2, 3, 5, 6, and 7
had all been answered in the negative, i.e., Ms. Maxwell did not have any sexual contact with the
Plaintiff (2), did not have sexual contact with any underage females (3), did not have any sexual
contact with anyone during a massage (4); had no knowledge of Epstein’s sexual activity other
than with Ms. Maxwell (5); had no knowledge of sexual activity with others and the Plaintiff
(6); and Ms. Maxwell’s knowledge of sexual activity of others with minors. Topics 4 and 8 had
been substantially answered, in the negative. The instruction not to not to answer questions
about sexual activity and massages was limited to any activity involving consensual adults. See
Plaintiff's Motion to Compel Deposition Questions at 10 (Doc. #143).
Given that the majority of the questions had already been posed and answered over a full
seven-hour time period one might reasonably assume that Ms. Maxwell’s second deposition
would be short and direct. Unfortunately, Plaintiff's counsel chose to ignore the Court’s Order,
repeatedly sought to reopen previously completed deposition topics and tried to ask questions
about new topics completely unrelated to the limited purpose authorized. Pagliuca Decl., Ex. D
(Transcript of (Second) Deposition of Ghislaine Maxwell on July 22, 2016). The entire
deposition was far beyond the specific request made by Plaintiff in her Motion that Ms. Maxwell
Extracted Information
Document Details
| Filename | Giuffre_Maxwell_Batch3_p00314.png |
| File Size | 308.8 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 2,166 characters |
| Indexed | 2026-02-04 12:39:50.850391 |