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DMIDTUBWNPFPOCODIDAGVBRWNHE Case 1:15-cv-07433-LAP Confidential Page 46 G. Maxwell - Confidential that what you're saying? A. I said I didn't really interact -- it's not that I didn't interact with her at all, but not enough for her to make a very strong and lasting impression. Q. Is it your testimony that you interacted with Virginia, but you didn't really interact with Virginia? MR. PAGLIUCA: Objection to form and foundation. A. I don't understand what that actually even means. Q. You said that you interacted with Virginia. Do you recall that? A. Inthe most general terms, I do recall her. Q. And then you testified that you didn't really interact with Virginia. Do you recall saying that? A. Iconsider this a real interaction. I will not be forgetting this any time soon. But the most casual of relationships, where you say hello or to be nice or polite, or offer someone a glass of water or something DMIDTUBWNPFPOCODIDAGVBRWNHE Document 1335-2 Filed 01/09/24 Page 14 of 73 Page 48 G. Maxwell - Confidential MR. PAGLIUCA: We've been going for about an hour this morning. I think you're probably aware that Ms. Maxwell was deposed for a full seven hours on a prior occasion. In my view, the court's order is limited and we shouldn't be covering ground that we covered in the prior deposition. At some point, we are going to need to call the court, if we go at this pace, for instruction about length of time here, because my view is that this is not supposed to be a seven-hour deposition, you are not supposed to be covering old ground, and you should be asking questions related to the, what I characterize as the eight discreet areas related to a, quote, sexual activity which precedes all of the eight items in the court's order of July 10th. We spent a lot of time not talking about those issues, and I suggest we get to it or we get the court on the phone for some guidance about timing here. Page 47 G. Maxwell - Confidential is what I would term a casual interaction. It is not something that, from what are we talking, 17, 18 years ago, something that really sticks out in my mind. Q. Is it your testimony that your only relationship with Virginia was what you referred to as a casual relationship where you might say hello or offer a glass of water to be polite? MR. PAGLIUCA: Objection to form and foundation. A. Generally, yes, that's how I would characterize. MR. PAGLIUCA: We've been going for about an hour. I would like to take a break. MR. BOIES: Certainly. THE VIDEOGRAPHER: The time is 10:01 a.m., and we are going off the record. (Recess.) THE VIDEOGRAPHER: The time is 10:10 a.m., and we are back on the record. This also begins DVD No. 2. MAGNAS ~ Page 49 G. Maxwell - Confidential MR. BOIES: I'm happy to get the court on the phone any time you like. I think the questions clearly relate to sexual activity. MR. PAGLIUCA: How old Virginia Roberts was or not does not relate to sexual activity. Her memory of how old Virginia Roberts may or may not have been does not relate to sexual activity, and it was all asked and answered in the prior deposition. MR. BOIES: Your witness introduced the subject, asserting that all of these people were adults. I didn't ask whether they were adults at that time. I simply asked a general question that was expressly covered by the judge's order. Your client opened the door, volunteered this and made it necessary to do this. I am happy to go to the court any time you want, and I'm happy to go over with the court some of these questions and put it in context for the court with (Pages 46 to 49) LEGAL SERVICES