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Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 9 of 12 involving Epstein;” (2) “questions relating to [Defendant’s] knowledge of sexual activities of others ... with or involving underage females known to Epstein or who Defendant believed were known or might become known to Epstein;” (3) “questions relating to [Defendant’s] knowledge of sexual activities of others . . . involving or including massage with individuals Defendant knew to be or believed might become known to Epstein.” Defendant also refused to answer foundational questions that are necessary precedent to the question authorized by this Court. The Court should direct Defendant to answer those questions, and all related questions that arise out of any response Defendant provides within the parameters of the Court’s June 20, 2016 Sealed Order. As recounted more fully in the moving brief, the questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should, again, compel Defendant to answer all these questions. Defendant claims that "[i]t is difficult to discern precisely what questions Plaintiff is complaining about in her Motion because of her generalized and non-specific complaints.” Br. at 9. To the contrary, Ms. Giuffre set forth excerpts from the deposition transcript showing exactly what questions Defendant refused to answer. To wit, Defendant failed to answer “So is it fair to say that Johanna was initially hired to answer telephones, according to your testimony?” (Plaintiff's Brief at 4); “So, how did it happen, Ms. Maxwell, that Joanna, who had been hired to answer the phones, ended up giving massages to you and Mr. Epstein?” (/d.); “Did Mr. Epstein pay Johanna for the massages that she gave Mr. Epstein?” (Plaintiff's Brief at 6); and “Do you know whether or not Maria Farmer was ever at Mr. Wexner’s property in Ohio?” (Plaintiffs Brief at 7). The brief also set for the instance wherein Mr. Pagliuca instructed the Defendant not