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Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 6 of 12 Tr. at 168:18 - 181:24. It appears that Defendant’s misleading tally of questions posed to her includes all the times questions were repeated or needlessly re-worded due to her obstructionist deposition tactics. Indeed, Defendant, who claimed her professional role with Epstein was to pay the pool guy,'° has a master’s degree from Oxford University’s Balliol College. Yet, throughout the deposition, she feigned incomprehension of basic questions, and even of basic words. Defendant pretended she did not know what a “puppet” is. See McCawley Decl at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 287-290. Other examples of Defendant’s feigned incomprehension of basic questions to avoid answering questions can be found attached at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 8:23-9:18 (pretending she did not know what a “female” is); 51:13 - 54:14 (pretending she didn’t understand what “sexual acts” were); 69:25-71:16 (pretending she doesn’t know what “sex toys” are); 87:8-91:3 (pretending that the dozens of police reports made by underage girls abused by Epstein were all “lies”). Defendant also repeatedly asked for simple questions to be rephrased, pretending that she did not understand. Specifically, she requested that questions be repeated or re-asked at least twenty-eight times. See McCawley Decl. at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 9, 13, 22, 26, 39, 50, 85, 93, 97, 98, 105, 121, 168-169, 187, 189, 201, 221 (two times), 239, 241, 257, 267, 278-279, 287, 289, 291, 336, and 377. Sometimes changing tact, she also asked for the questions to be broken down/apart. See McCawley Decl. at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 26, 93-94, 168-169, 170. Defendant is correct that there was much repetition in her deposition: many questions were asked multiple times when Defendant did not provide an answer, and many were asked multiple times at Defendant’s own request. 16 See McCawley Decl. at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 50:18-24. 6