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Case 1:15-cv-07433-LAP Document 1332-14 Filed 01/08/24 Page 2 of 9 Plaintiff, Ms. Virginia Giuffre, respectfully submits this memorandum of law in response and opposition to Defendant’s Motion to Appoint a Special Master to Preside Over the Third Deposition of Defendant. BACKGROUND Defendant’s recounting of the certain background facts obscures the fact that the Court has entered two separate orders, each of which require a deposition of not more than two hours of Defendant. Accordingly, the upcoming deposition will not exceed a total of four hours. The two separate issues relate to (1) Defendant’s failure to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. Defendant’s Failure to Answer Certain Questions During her first deposition, Defendant improperly refused to answer certain questions. Accordingly, the Court ordered a second deposition, directing the Defendant to answer questions on several enumerated topics: Defendant is ordered to answer questions relating to Defendant's own sexual activity (a) with or involving Jeffrey Epstein (“Epstein”), (b) with or involving Plaintiff, (c) with or involving underage females known to Epstein or who Defendant believed or intended might become known to Epstein, or (d) involving or including massage with individuals Defendant knew to be, or believed might become, known to Epstein . Defendant is also directed to answer questions relating to her knowledge of sexual activities of others (a) with or involving Epstein, (b) with or involving Plaintiff, (c) with or involving underage females known to Epstein or who Defendant believed were known or might become known to Epstein, or (d) involving or including massage with individuals Defendant knew to be or believed might become known to Epstein. The scope of Defendant's answers are not bound by time period, though Defendant need not answer questions that relate to none of these subjects or that is clearly not relevant, such as sexual activity of third- parties who bear no knowledge or relation to the key events, individuals, or locations of this case. Sealed Order June 20, 2016 at 9-10.