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Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 8 of 27 “trafficked” to third party dignitaries, politicians and academics.’ Suffice it to say, had the defamation matter proceeded to trial, Ms. Maxwell would have had no difficulty demonstrating that Ms. Giuffre had publicly made allegations that were “untrue” and “obvious lies,” defeating any civil liability. Because Giuffre could not prove the truth of her own statements, she and her lawyers attempted to convert what should have been a relatively straightforward factual question—the truth of Ms. Maxwell’s denial of Giuffre’s fantastical allegations—into a claim that Giuffre was “sexually trafficked” by Epstein to other men. This attempt, however, involved inadmissible and improper evidence, which was the subject of approximately 50 motions that remained undecided at the time that the defamation action was dismissed. B. Ms. Maxwell’s Depositions It is in this context—a weak defamation claim—that Ms. Maxwell was deposed twice. Before her first deposition, however, the Court granted at Ms. Maxwell’s request a protective order to shield any “confidential” information from what was sure to be a high-publicity, media circus. Case No. 15-cv-7433, Doc. # 38. Plaintiff opposed Ms. Maxwell’s proposed protective order, instead urging the Court to permit disclosure of “confidential” information in relation to “investigations by law enforcement.” /d., Doc. # 40 at 3-4. Ms. Maxwell opposed this provision, and ultimately, the Protective Order was entered without Giuffre’s proposed law enforcement exception. Ex. G. 3 At present in a neighboring courtroom, Ms. Giuffre is embroiled in another defamation suit, this time against Professor Alan Dershowitz. See Giuffre v. Dewrshowitz, Case No. 19-cv-3377-LAP. But Professor Dershowitz has counterclaimed against her for defamation and related torts. /d. Doc. #90 & 127. In that matter, Professor Dershowitz recently filed an affidavit and transcript which document the reporter to whom Ms. Giuffre sold her story about Epstein and Maxwell revealing that she believes Ms. Giuffre and her lawyers fabricated evidence including her story about Professor Dershowitz. /d. at Doc. # 210-1, 210-2. DOJ-OGR-00002417