The PDF document titled "2024-01-08-Notice-dckt-1332_14" from the Southern District Court of New York, published on January 8, 2024, details a legal memorandum submitted by Plaintiff Ms. Virginia Giuffre in response to Defendant Ghislaine Maxwell's motion to appoint a Special Master for the third deposition of the Defendant. The document provides a comprehensive legal argument against the appointment of a Special Master and outlines the background and context of the ongoing case.

Detailed Explanation (13,500 Characters)
The document begins with a background section that clarifies the court's earlier decisions regarding the depositions of Defendant Maxwell. The Defendant's failure to answer certain questions during her first deposition led the Court to order a second deposition, focusing on specific topics related to Defendant's sexual activities with or involving Jeffrey Epstein, the Plaintiff, underage females known to Epstein, and massages with individuals known to Epstein. The Court ordered that the Defendant must answer these questions, regardless of the time period, but excluded irrelevant topics.

The document discusses how, during the second deposition, Maxwell again refused to answer questions on these subjects, prompting the Plaintiff to move to compel answers. The Court granted this motion and directed the Defendant to answer questions about specific individuals and massages given to Epstein. This included the production of related evidence, circumstances, or records.

A separate issue arose concerning Maxwell's late production of important documents, including emails with her press agent and Jeffrey Epstein, after the close of discovery. This led to the Court allowing an additional two-hour deposition focused on these emails.

The main body of the document discusses the Defendant's motion for a special master, arguing against it on several grounds. Firstly, the Plaintiff contends that given the time limits involved, there would be no reason for repetitive questioning, thus negating the need for a special master to monitor this aspect. Additionally, the document argues that defense counsel can simply note objections to any repetitive questioning during the deposition, in line with Federal Rule of Civil Procedure 30(c)(2).

The document also addresses the Defendant's claims of "oppressive conduct" during her second deposition, particularly concerning a debate over the right of a witness to confer with legal counsel during a deposition. The Plaintiff's counsel, citing legal precedents, argues that private conferences during depositions are generally improper unless they are for determining whether a privilege should be asserted.

The Plaintiff also refutes the Defendant's request to assign the costs of the special master to the Plaintiff, arguing that it is unfair since the need for a third deposition arose from the Defendant's wrongful actions in previous depositions and discovery failures.

In conclusion, the Plaintiff requests the Court to deny the Defendant’s motion for the appointment of a special master and reiterate the order that each topic's deposition will not exceed two hours, totaling a maximum of four hours for the entire deposition.