Giuffre_Maxwell_Batch8_p00286.png

Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 285 of 465 Page 284 G Maxwell - Confidential calls for a communication that you had with one of your lawyers, I'm instructing you not to answer that question. Q. I assume you, as part of the discovery process, had to collect documents that were relevant to this action, is that correct? A. I did. Q. Did you collect documents that would show that Virginia was 17 at the time that you met her? A. I think you have everything that relates, that I had, contemporaneously per what you asked for that I have that relates to that. Q. Did you have a document that identified that Virginia was 17 at the time that you met her? A. You have all of the documents that Q. I'm not asking what documents. I'm asking, do you have a document that identifies Virginia being 17 at the time you MAGNA® LEGAL SERVICES