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Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 22 of 73 Confidential Page 78 G. Maxwell - Confidential Johanna? A. I would not know. I would say no. Q. Did you engage in sexual activities with Johanna? A. No. Q. Do you know how Johanna came to know Mr. Epstein? A. I met her at her university and she came to answer phones. Q. When you say she came to answer phones, where? A. In Palm Beach. Q. At Mr. Epstein's home in Palm Beach? A. Yes. Q. So is it fair to say that Johanna was initially hired to answer telephones, according to your testimony? MR. PAGLIUCA: This has already been testified to Mr. Boies. We are repeating testimony now. MR. BOIES: I think in the context of the witness' answers, these are fair questions. DMIDTUBWNPFPOCODIDAGVBRWNHE DMIDTUBWNPFPOCODIDAGVBRWNHE Page 80 G. Maxwell - Confidential instructed that the right way to do it was to bring any issue to him after the conclusion of the deposition. The question that has been raised is whether we should interrupt the deposition now and seek guidance of the court before continuing the deposition. My view is that the deposition needs to continue, and the counsel for the defendant can instruct not to answer and any questions that are instructed not to answer can be brought to the court, but I would not consent to terminating the deposition at this point. MR. PAGLIUCA: I don't know if it's a matter of consent or not. If I move for a protective order, the deposition is over and we can go litigate it in front of Judge Sweet. We are here and I'd like to complete this deposition because this case needs to move along, and quite frankly, I don't want to spend money coming back here to do this again Page 79 G. Maxwell - Confidential Now, I've asked you before, if you want to instruct her not to answer, if you want to go to the judge, we are happy to do that, but I would suggest, in the interest of moving it along, that you stop these speeches. MR. PAGLIUCA: You are not moving it along is the problem, so maybe we should call the court and get some direction here, because I am not going to sit here and rehash the testimony we already gave. MR. BOIES: That's fine. THE VIDEOGRAPHER: The time is 10:51 a.m. and we are going off the record. (Whereupon, an off-the-record discussion was held.) THE VIDEOGRAPHER: The time is 10:56 a.m. and we are going back on the record. This begins DVD No. 3. MR. BOIES: We have just had a call with Judge Sweet's chambers, Judge Sweet is not available and his chambers Page 81 G. Maxwell - Confidential or argue this in front of Judge Sweet. But I will simply start referring you back to the transcript and instructing the witness not to answer when I think we are getting into some things that have been asked and answered already. MR. BOIES: Exactly the procedure that I have proposed from the beginning. If you think a question is out of bounds, instruct not to answer and we will then let the judge decide it. BY MR. BOIES: Q. How did it happen, Ms. Maxwell, that Johanna, who had been hired to answer the phones, ended up giving massages to you and Mr. Epstein? MR. PAGLIUCA: I'm going to instruct you not to answer the question. This has been previously, the subject of your former deposition, it doesn't fall into any of the categories ordered by the court, and so you don't need to answer that. MAGNA®© 21 (Pages 78 to 81) LEGAL SERVICES