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Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 5 of 12 times. She also spent much of her time feigning incomprehension of simple sentences and common words, also causing the same question to be posed to her multiple times. For example, defendant pretended not to understand the question, “Do you believe that Epstein abused minors?,” causing it to be repeated multiple times. Q. ... do you believe that Jeffrey Epstein abused any minor children? A. Can you repeat the question please and break it down so it's more understandable. Q. Now that you have the police report that I showed you this morning that you had an opportunity to look at. A. You gave it to me, I did not look at it. Q. The questions that I asked you about the police report -- you are aware there is a police report? A. Lam aware there is a police report. Q. You are aware there was a criminal investigation of Jeffrey Epstein? A. Lam aware that there was that. Q. Now that you are aware of those two things and having talked to Jeffrey Epstein, do you believe Jeffrey Epstein sexually abused minors? A. Can you reask the second part of that question please. Q. Sure. The two documents we were talking about, the document and the investigation, you said you are aware of and after having talked to Jeffrey Epstein, do you believe Jeffrey Epstein sexually abused minors? A. What do you mean I talked to Jeffrey, you need to break the question down further. RR Q. Let's take those two things. After knowing those two things, do you believe that Jeffrey Epstein abused minor children? A. Can you explain what you mean by the question actually. Q. I think the question speaks for itself. I will try again. I will say it one more time because I want you to be able to understand it. Knowing that you have the police report here and knowing about the criminal investigation, do you believe that Jeffrey Epstein sexually abused minors? This sequence goes on and on. Counsel for Ms. Giuffre had to ask Defendant whether she believed Epstein abused minors fourteen more times after this exchange. '° Still, Defendant never answered the question. See McCawley Decl. at Exhibit 1, Maxwell’s April 22, 2016 Dep. S See McCawley Decl. at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 170, 171, 173 (twice), 174 (twice), 175 (twice), 176 (twice), 178, 182 (twice), and 183. Counsel for Ms. Giuffre had to repeat other questions when Defendant did not answer them (e.g., asking about Defendant’s knowledge of abuse of minors in Epstein’s home, See McCawley Dec. at Exhibit 1, Maxwell’s April 22, 2016 Dep. Tr. at 90, 168-169).