Giuffre_Maxwell_Batch7_p00273.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1332-12 Filed 01/08/24 Page 3 of 7
(d) other women who gave massages to Jeffrey Epstein, and any evidence, circumstances,
or records relating to the massages.
Order of Nov. 2, 2016 at 7.
During the hearing on November 10, 2016, this Court granted Plaintiff's Motion to
permit this third deposition to include questioning concerning two emails produced August 16,
2016 (Doc. # 466); see Tr. of Nov. 10, 2016 hearing at 34.
On November 15, 2016, Defendant moved for reconsideration or clarification of portions
of the November 2, 2016 Order. With respect to the third deposition of Ms. Maxwell, the Court
granted the motion for clarification, which requested that the Court clarify that the deposition
would be limited to non-duplicative questioning “limited to the four areas of inquiry referred to
in the Order at page 7.” Sealed Order of March 23, 2017 at 4.!
Pursuant to Fed. R. Civ. P. 53, the Court may appoint a special master to “address pretrial
and post-trial matters that cannot be effectively and timely addressed by an available district
judge or magistrate judge of the district.” In light of the trial in this matter scheduled to begin
May 15, 2017, it is in all parties’ best interest to complete this final two hours of deposition
quickly and efficiently. Given that in the prior depositions of Ms. Maxwell, counsel for Plaintiff
has repeatedly covered the same questions, we believe that there is a high likelihood that this
repetitive duplicative questioning will occur again, necessitating objections by counsel to enforce
this Court March 23, 2017 Order, as is permitted by Fed. R. Civ. P. 30(c)(2). Should this occur,
an immediate ruling on the issue by a special master would prevent the need for any further
briefings on these matters, whether by Motion for Protective Order or otherwise.
' Because the Order pertaining to reopening the deposition concerning the two emails occurred after the
November 2, 2016 Order, it was not addressed in the Motion for Reconsideration, and therefore not identified as one
of the limited topics of the third deposition. It is clear from the hearing transcript, however, that the Court and
counsel recognized that these topics would be covered in the same additional two-hour deposition.
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Document Details
| Filename | Giuffre_Maxwell_Batch7_p00273.png |
| File Size | 311.3 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 2,286 characters |
| Indexed | 2026-02-04 12:48:25.228616 |