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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 15 of 27 Il. COUNSEL INSTRUCTED MAXWELL NOT TO ANSWER TO ENFORCE THE COURT’S ORDER AND TO PREVENT HARASSMENT BY PLAINTIFF’S COUNSEL The only questions to which counsel for Ms. Maxwell instructed her not to answer were those that she had already answered or were outside the Court’s Order permitting a re-opening of the deposition. Fed. R. Civ. P. 30(c)(2) (instruction not to answer appropriate “when necessary to ... enforce a limitation ordered by the court”). Plaintiff loosely points to eleven questions in her Motion. She omits parts in which the question had already been answered, and she implies an instruction not to answer where none was given. None of the cited questions merits the re- opening of Ms. Maxwell’s deposition for a third bite at the apple. A. Objected to Question Number 1: “So how did it happen, Ms. Maxwell, that Joanna, who had been hired to answer phones, ended up giving massages to you and Mr. Epstein.” In Ms. Maxwell’s first, 7 hour, deposition she was questioned extensively about her relationship with Ms. Sjoberg. See Pagliuca Decl. Ex. C at 59-63; 112-113; & 307-309. Consistent with the Defendant’s position at that time, Plaintiff was free to ask, and asked, questions about Ms.Sjoberg with the exception of consensual adult sexual contact. The only instruction to not answer was limited to consensual adult sexual contact, of which there was none. (Although in fact, Ms. Maxwell testified in her first deposition that the massages with Ms. Sjoberg did not involve sex.). See Pagliuca Decl. Ex. C at 61:14-15.. In Ms. Maxwell’s second, 4.5 hour deposition, she was again questioned extensively about Ms. Sjoberg. The questioning begins on page 74 of the transcript. Plaintiff's counsel asked dozens of questions about Ms. Sjoberg without any instruction to not answer. When the questions became repetitive to the questions asked at the first deposition and strayed outside the