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Giuffre_Maxwell_Batch3_p00324.png

Source: GIUFFRE_MAXWELL  •  Size: 257.5 KB  •  OCR Confidence: 95.0%
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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 18 of 27 second deposition, the same Exhibit 13 was introduced and Ms. Maxwell was asked, without objection, questions relating to specific names on Exhibit 13. See Pagliuca Decl., Ex. C at 312- 334 and Ex. D at 179- 89. Exhibit 13 was a document prepared by someone other than Ms. Maxwell, was not maintained by Ms. Maxwell and over which Ms. Maxwell had no control. Given the extensive testimony on the subject in both depositions, it was appropriate to instruct the witness to not answer the question. This debate, however is unnecessary because the question was asked again in a slightly different form and answered: Q: “Did you, or insofar as you are aware anyone, maintain a list of females that provided massage services to Mr. Epstein at his residences?” A: “I don’t know anything about a list.” /d., Ex. D at 185:13-20. No follow up questions were asked after this answer. F. Objected to Question Number 7 “In 2005, were you aware of any effort to destroy records of messages you had taken of women who had called Mr. Epstein in the prior period?” Ms. Maxwell was previously deposed about documents purportedly seized when Mr. Epstein’s house was searched by the Palm Beach Police Department. See Pagliuca Decl., Ex. C at 312-19. The Court’s June 20, Order did not reopen the deposition to allow for baseless questions about the destruction of evidence in 2005. Alleged destruction of records has nothing to do with any of the 8 areas that the Court addressed. Accordingly, the objection is well founded. Plaintiff's tortured explanation about how the question fits into the Court’s Order is nonsense.

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Filename Giuffre_Maxwell_Batch3_p00324.png
File Size 257.5 KB
OCR Confidence 95.0%
Has Readable Text Yes
Text Length 1,677 characters
Indexed 2026-02-04 12:39:53.036574