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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 14 of 27 additional 4.5 hours permitted in the second deposition and the fact that she answered in the second deposition the only pertinent questions permitted by the Court Order. See Fed. R. Civ. P. 30(d)(1) (“the court must allow additional time consistent with Rule 26(b)(1) and (2) if needed to fairly examine the deponent”) (emphasis added). Rule 30(d)(1) requires a court to guard against redundant or disproportionate discovery, stating that any additional deposition time must be consistent with Rule 26(b)(1) and (2), prohibiting, among other things, cumulative and duplicative testimony. The duplicative nature of the “topics” requested by Plaintiff is demonstrated by the previously cited testimony. It is compounded by the fact that Ms. Sjoberg has fully testified concerning how she came to work for Epstein, what she did while working for him, and how she was paid. See This Response at 20-21, infra. The redundancy of the requested testimony (much of which is outside the scope of the Order) prohibits a finding of good cause for reopening — yet again — Ms. Maxwell’s testimony. See Kleppinger v. Texas Dep't of Transp., 283 F.R.D. 330, 333 (S.D. Tex. 2012) (“a party seeking a court order to extend the duration of the examination must show ‘good cause’ to justify such an order” including showing information is not duplicative and cumulative). Of course, Ms. Maxwell and her counsel had no desire to subject Ms. Maxwell to a third deposition, thus permitting many questions that far exceeded the scope of the Order. When called on to explain how extraneous questions were proper, Plaintiffs counsel refused to proffer why certain questions were within the Court’s order leaving Ms. Maxwell’s counsel no option, on a few occasions, to instruct Ms. Maxwell to not answer. Plaintiffs counsel’s refusal to simply explain how objectionable questions were within the scope of the permitted deposition makes clear that they were not, and should act as a waiver. See, e.g., Pagliuca Decl., Ex. D at 99-101. 12