Giuffre_Maxwell_Batch3_p00323.png
Extracted Text (OCR)
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the question was within the Court’s Order, the question was withdrawn and a different question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
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Dates
Document Details
| 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 |