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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 13 of 27 Second, Plaintiff inaccurately complains that Ms. Maxwell refused to answer questions concerning sexual activity involving two women named Annie and Maria Farmer. Motion at 6. Not so. Ms. Maxwell answered questions for fully 13 pages of her deposition concerning the Farmers. See Pagliuca Decl., Ex. D at 95-98 and 103-113. Ms. Maxwell answered well over 76 questions relating to Annie and Maria Farmer including who they are, when she met them, whether she ever saw them at Epstein’s homes or her own home, whether Epstein ever had sex with them, whether they worked for Epstein, whether they flew on planes together, gave or received massages, participated in any sexual activities with one another, where they lived, the description of their living environments, and whether journalist Vicky Ward ever told Ms. Maxwell that Epstein had engaged in sexual activities. Jd. This was on top of the questions that Ms. Maxwell had already answered at her first deposition that were nearly identical: who are the Farmers, how did you meet them, whether they ever made any allegations of sexual abuse by Epstein, or whether Ms. Maxwell had ever had non-consensual sexual contact with Annie Farmer. Pagliuca Decl., Ex. C at 95:14 -98:10 & 103:19-113:22. In fact, at the first deposition, Ms. Maxwell did not refuse to answer a single question regarding the Farmers. Thus, all of the questions at the second deposition were redundant, cumulative and outside of the Court’s Order. The only question that Ms. Maxwell refused to answer was: “What did Vicky Ward tell you about Maria Farmer when she talked to you?,” after which she answered another 10 pages of questions that centered around whether Vicky Ward had said specific things regarding the Farmers. Pagliuca Decl., Ex. D at 103-113. Ms. Maxwell has already flatly denied she had any knowledge of the allegations posited by reporter Vicky Ward. Plaintiff is not permitted to re-depose Ms. Maxwell on issues already covered, or which she had the opportunity to cover, in the first 7-hour deposition, particularly in light of the