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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 8 of 12 giving drafts to Epstein for his approval. Accordingly, Defendant was never deposed on (1) why she was seeking Epstein’s permission for having Barden make a “reply;” (2) what Epstein’s relationship was with Barden; (3) or who drafted the original communication at the bottom of the email, as it does not appear to have been created by either Defendant or Epstein. As Plaintiff is fully aware, Ms. Maxwell already fully deposed on “(1) why she was 999, seeking Epstein’s permission for having Barden make a ‘reply’”; any claim to the contrary is simply false. Ms. Maxwell produced (prior to her depositions) several similar communications between herself and Mr. Epstein in which she sought input from Mr. Epstein on having her attorney, Mr. Barden, respond to allegations made by Plaintiff concerning Ms. Maxwell. Indeed in one email, Mr. Epstein advised Ms. Maxwell to go out and hold her head high because she had done nothing wrong. See Menninger Decl., Ex. D [GM_01069-01072; 01075; 01084-01099]. Further, Ms. Maxwell was specifically deposed on this issue:! (Maxwell Exhibit 23, email, marked for identification.) Q. This is an email from, if you look at the chain at the top, you will see it's from you to Jeffrey on January 27 and the email at the bottom of the chain is from Jeffrey to you on January 27. He states, What happened to you and your statement, question mark, question mark. And you put at the top, I have not decided what to do. A. Uh-huh. Q. Why was Jeffrey interested in you making a statement to the press? A. I don't know that he was interested. We made a statement and then I was being advised to make an additional statement and I never did. Q. Was Jeffrey communicating with you regularly on what additional statement you might make? A. No, I've communicated with him very little, as little as possible. Q. Why did you feel you had to keep him informed of statements you were making to the press? A. I didn't feel I had to. ' As to the substance of the email — Plaintiff's fabricated claim that Mr. Epstein and Ms. Maxwell requested Plaintiff to bear a child for them — Ms. Maxwell was extensively questioned in her first deposition. Menninger Decl. Ex. A, at 337-39.