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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 19 of 27 G. Objection to Question Number 8 “In terms of preparing for this deposition, what documents did you review?” Ms. Maxwell was instructed to not answer the question as it related to privileged communications between Ms. Maxwell and counsel. Ms. Maxwell was asked if any of the documents refreshed her recollection about any of the events that occurred. Her response was: “No.” A follow up question was asked as to whether counsel provided Ms. Maxwell with any documents and the answer was “One, I believe.” The communication between Ms. Maxwell and counsel was privileged, did not refresh her recollection, and the question was properly objected to. H. Objections to Questions 9, 10, and 11. “Now have you ever engaged in oral sex?” “Did you ever have oral sex with anyone in any of Mr. Epstein’s five homes that you’ve identified other than Mr. Epstein?” “Did you, in the 1990s and 2000s, engage in sexual activities other than intercourse with women other than what you have testified already?” All of these questions were prohibited by the Court’s Order because they were related to unidentified “third-parties who bear no knowledge or relation to the key events, individuals, or locations of this case.” The question “Now have you ever engaged in oral sex?” is not tied to any person place, event or time. It is clearly out of bounds. Ms. Maxwell did, in fact, answer the question about oral sex with individuals other than Mr. Epstein when the locations were specified, i.e, planes; New York; Palm Beach; New Mexico; Paris; and the Virgin Islands. See Pagliuca Decl., Ex. D, Excerpts from July22, 2016 Maxwell Deposition pp. 21-23. (The answer was “no”.).