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Case 18-2868, Document 276, 08/09/2019, 2628224, Page11 of 77 said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. See id. at 6-7. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary,” id. at 7. Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because, as the court pointed out, the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. See id. at 7-8; see also id. at 8 (noting that in the motion, Ms. Giuffre’s lawyers said that “regardless of whether this Court grants the . . . Motion, ‘they will call [her] as a witness at any trial”). The court denied plaintiff's joinder motion. /d. at 10. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. EXHIBIT D, at 3-6. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: e =©Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Id. at 3. e Ms. Maxwell was “one of the main women” Epstein used to “procure under- aged girls for sexual activities.” Jd. e = Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. Jd. e She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” /d. e At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” /d. e Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into ...a “sex slave.’” Jd. Plaintiff was a “sex slave” from “about 1999 through 2002.” Id. e Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Jd. at 4.