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Case 1:15-cv-07433-LAP Document 1332-14 Filed 01/08/24 Page 4 of 9 including Defendant’s coordination of the press attack on Ms. Giuffre and Defendant’s coordination of the attack with her co-conspirator, Epstein. The Court heard oral argument on Ms. Giuffre’s motion on November 10, 2016. After argument, the Court agreed with Ms. Giuffre and ruled as follows: “Ms. Maxwell will be deposed with respect to the emails. The deposition will be limited to two hours.” Sealed Transcript, Nov. 10, 2016, at 34. DISCUSSION Defendant now moves for appointment of a special master, offering two arguments. First, Defendant claims that she is concerned about “repetitive duplicative questioning” of certain subjects. Mot. at 2. Of course, given the time limits involved, Ms. Giuffre’s counsel would have no reason to engage in such repetitive questioning. But, in any event, there is no need for a special master to be involved in deciding whether questioning is somehow repetitive. Defense counsel can simply note an objection to that effect, and the deposition will move forward. See Fed. R. Civ. P. 30(c)(2). A special master is not needed — and would, of course, have great difficulty in getting up to speed on what subjects might or might not be regarded as repetitive. Second, Defendant claims that she has been subject to “oppressive conduct” during her second deposition, citing an approximately one-minute long passage in the deposition with Ms. Giuffre’s counsel, David Boies, indicated his view that caselaw did not permit a witness to substantively confer with legal counsel during the middle of a deposition. Defense counsel took the opposite view. On this point, Mr. Boies was correct. It is hornbook law that once a deposition begins, however, an attorney and a client do not have an absolute right to confer. Rather, a private conference between a deponent and the