DocumentCloud_Epstein_Docs_p00843.png

Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor.”° The dates on the hospital records show she was seventeen years old. 5. Judith Lightfoot Psychological Records As the Court is aware, Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records in a fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75); Defendant’s Motion for Sanctions at 10 (““Ms. Maxwell has been severely prejudiced by Plaintiff's failure to provide the required identifying information and documents from her health care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers, spanning two continents and nearly two decades. Now that those records have been collected, Defendant’s 68 page motion makes no reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre. Defendant’s requests unearthed documents that are highly unfavorable to Defendant that corroborate Ms. Giuffre’s claims against her. Years before this cause of action arose, Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser: 5 See McCawley Dec at Exhibit 33, GIUFFRE003259-003290. 16