Giuffre_Maxwell_Batch3_p00324.png
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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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Dates
Document Details
| 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 |