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Giuffre_Maxwell_Batch3_p00323.png

Source: GIUFFRE_MAXWELL  •  Size: 291.7 KB  •  OCR Confidence: 95.3%
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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 17 of 27 Cc. “Objected” to Question Number 4. “Do you know if Maria Farmer was ever at Mr. Wexner’s property in Ohio?” This question is completely outside the Court’s June 20, 2016 Order as it does not relate to Ms. Maxwell, Mr. Epstein, massages, sex, or any property identified in this case. Regardless, the witness was never instructed to not answer the question and did not refuse to answer questions about the Farmers. After the question was posed, counsel for Ms. Maxwell simply asked for an explanation as to how the question was within the Court’s Order. The witness was not instructed not to answer. It appears that after considering the request for a proffer as to how the question was within the Court’s Order, the question was withdrawn and a different question was posed: “Mr. Boies: Let me approach it this way.” ... Did Ms. Ward tell you that?” The questioning about the Farmers continues many pages thereafter. See Pagliuca Decl., Ex. D at 99- 113. D. “Objected” to Question Number 5 Without any record support Plaintiff claims that “Defendant’s counsel also stopped a line of questioning in which defendant was asked if she recalled several girls Tony Figueroa brought over to give a ‘massage’ to Epstein.” Plaintiff cites no specific instruction not to answer because one was never given. Ms. Maxwell answered questions about Mr. Figueroa and was questioned extensively regarding lists of names, about which Ms. Maxwell had no knowledge. Plaintiff was not forced to “cease questioning” about any person. The questioning occurred and Ms. Maxwell responded. E. “Objected” to Question Number 6 “Was there a list that was kept of women or girls who provided massages?” The “list” was introduced as Exhibit 13 to Ms. Maxwell’s first deposition. Ms. Maxwell was questioned extensively about the “list” and testified, without objection about the list. In her 15

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Filename Giuffre_Maxwell_Batch3_p00323.png
File Size 291.7 KB
OCR Confidence 95.3%
Has Readable Text Yes
Text Length 1,942 characters
Indexed 2026-02-04 12:39:53.231840