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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 145 of 239 Gow stated that Giuffre’s claims were “untrue” and “obvious lies.” (15 Civ. 7433 (LAP), Dkt. No. | at 6). As described in the preceding section, in the fall of 2015, Giuffre sued the defendant for defamation.*° (See 15 Civ. 7433 (LAP), Dkt. No. 1). Giuffre alleged that Epstein sexually abused her, “with the assistance and participation of Maxwell” at “numerous locations” between 1999 and 2002, and that Epstein abused more than thirty minors between 2001 and 2007 “with the assistance of numerous co-conspirators.” (/d. at 3). During the defendant’s first deposition on April 22, 2016, the defendant refused to answer questions that she deemed related to consensual adult sexual interactions. (See, e.g., Ex. 10 at 92:20-93:6). Giuffre moved to compel the defendant to answer, explaining that “[a]t the core of [her] allegations is the allegation that [the] Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually tried to turn massages into sex .. . and that Maxwell recruited other females for an ostensibly proper position, such as therapeutic masseuse, with knowledge that the intent was for that person would be pressured to provide sexual gratification to Epstein.” (15 Civ. 7443 (LAP), Dkt. No. 1137-1 at 5- 6). Giuffre also explained that the defendant’s refusal to answer questions about adult consensual sex prevented Giuffre “from seeking legitimate discovery,” such as the identity of people the defendant presently deemed adults. (/d. at 6). The Court granted Giuffre’s motion. “[N]otwithstanding” the intrusiveness of the questions and the fact that the defendant had not put her private affairs at issue, “the questions are directed to reveal relevant answers regarding Defendant’s knowledge of Plaintiff’s allegations.” “© The below discussion is provided as context for the Court’s consideration of the motion. As discussed further in the Government’s opposition to the defendant’s motion for severance, the Government expects to provide a more streamlined presentation regarding the Giuffre suit at trial. 118 DOJ-OGR-00003079