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Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 10 of 12 to answer any more questions with respect to whether she knows certain girls who came over to Epstein’s home to massage him, “Q. Have you ever heard the name Carolyn Andriamo, A-N-D- R-I-A-M-O? A. I don’t recollect that name at all. MR. PAGLIUCA: those names are on Exhibit 26, which we have already gone over and she said she didn't recognize those people, so now we are just repeating things that we went over. MR. BOIES: I am in the context of seeing if I can refresh her recollection, because these are women that Mr. Figueroa, who she also does not recall, brought over to Mr. Epstein's residences, and I also want to make a very clear record of what her testimony is and is not right now.” (Plaintiffs Brief at 8-9). See McCawley Dec. at Exhibit 3, Excerpts from Maxwell July 22, 2016 Dep. Tr. at 154-156. Defendant cannot make a credible argument that these questions, or their subject matter, are outside the scope of the Court’s Order. All of them relate to Defendant’s knowledge of individuals who “massaged” Jeffrey Epstein (Johanna Sjoberg), who were brought to their house to “massage” Jeffrey Epstein (Carolyn Andriamo and myriad other girls who Figueroa brought at Defendant’s behest); and who were massaged by Defendant herself (Annie Farmer at 16 and Maria Farmer). Mr. Boies’ unanswered questions are all directly within the ambit of this Court’s Order. Again, Defendant’s arguments do not change the language of this Court’s Order; nor do they change the questions Defendant refused to answer. Defendant must answer these questions. I. CONCLUSION Based upon the foregoing, Ms. Giuffre respectfully requests that this Court grant her Motion, and direct the Defendant to answer the disposition questions Mr. Boies posed to her. Dated: August 12, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP 10