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Case 1:15-cv-07433-LAP Document 1332-12 Filed 01/08/24 Page 2 of 7 Defendant Ghislaine Maxwell (““Ms. Maxwell”), pursuant to Federal Rule of Civil Procedure 53, files this Motion to Appoint a Special Master to Preside over the Third Deposition of Defendant Ghislaine Maxwell, and states as follows: STATEMENT OF CONFERRAL The undersigned has conferred with counsel for Plaintiff, who stated that they do not agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition. INTRODUCTION Plaintiff has deposed Defendant for more than thirteen hours of testimony on the record. During the previous depositions, a variety of issues arose, including repetitive and duplicative questioning on a variety of subjects outside of the Court’s previous orders, resulting in the need for objections to the questioning and instructions not to answer. The Court has permitted Ms. Maxwell to be deposed for a third time, on limited subject areas, limited to non-duplicative examination, for a maximum of two hours. To avoid the possibility of any request for yet another deposition of Ms. Maxwell, we submit it is in the best interest of all parties to appoint a special master to preside over the deposition to provide immediate rulings on any objections that may arise regarding questions that are outside of the scope of the deposition as set forth in this Court’s March 23, 2017 and November 10, 2016 Orders, or any other issues that might arise during the deposition. L THE SCOPE OF THE DEPOSITION On November 2, 2016, the Court granted Plaintiff's Motion to permit a third deposition of Ms. Maxwell concerning the following subjects: (a) Johanna Sjoberg , (b) Maria and Annie Farmer, (c) women brought by Tony Figueroa ,